PAPER 2 HAVE YOUR SAY

‘HAVE YOUR SAY’ GOVERNMENT CONSULTATION ON NOMINATION OF SITES FOR NEW NUCLEAR POWER STATIONS

RESPONSE TO THE CONSULTATION BY BLACKWATER AGAINST NEW NUCLEAR GROUP (BANNG)

1. Nature of this Response

The Blackwater Against New Nuclear Group (BANNG) is a Citizens’ Based Organisation formed in early 2008 to oppose the proposed development of a new nuclear power station at Bradwell. The Aims and Purpose of the Group are set out in Appendix 2. The Group has already made substantial responses to the consultations on the Strategic Siting Assessment criteria and on the NIA’s Application to Justify New Nuclear Power stations. Those responses cover at a generic level a number of issues which are relevant to individual sites. This present response focuses specifically on Bradwell and follows on from our previous responses. We wish all three responses to be taken into account by government when considering the suitability of the site for listing in the draft Nuclear National Policy Statement.

The purpose of the ‘Have Your Say’ consultation is unclear. It is not a formal consultation. It appears as an afterthought added on to help legitimate the overall siting programme (see our comments on legitimation in our SSA response). The one month period following nomination of sites is wholly inadequate for CBOs to make a fully considered and detailed response. It is particularly difficult for communities near sites whose nomination could not have been anticipated. Responses to this consultation must be regarded as provisional and preliminary. BANNG considers much more time and support should be given for CBOs and other interested parties to make a full and considered response to the siting proposals.

The method of response suggested by DECC on its website seems to us unduly structured and constrained. The response form is structured in terms of the government’s strategic siting assessment criteria (DECC, 2009) which tends to constrain responses along predetermined lines. BANNG objects strongly to this approach and this response emphasises those issues we consider are most pertinent to the Bradwell proposal and includes issues that are not covered in the response form. BANNG considers the method of response indicated by government to be inhibiting and inflexible and likely to limit the issues considered.

However, this consultation does provide an opportunity for the fundamental problems with individual sites to be identified and for government to reject any nominated sites that clearly have little hope of proceeding successfully through the planning process.

BANNG considers that assessed against the criteria Bradwell is a most unsuitable site for a new nuclear power station and long term waste management stores. We set out our reasons in this response. We, therefore, urge the government to reject the site. However, if it is decided to list the site we request that the reasons for its acceptance are set out along with the reasons why the objections by us and others have been rejected.

Appendix 1 is a summary of the recommendations in this response.

2. Concerns about the Consultation Process so far

We have set out in detail in our previous responses our concerns about the consultation processes being undertaken with respect to new build. In our submission on the SSA criteria we argued that the consultation undertaken by nuclear operators, in this case British Energy, was quite inadequate. A series of public meetings, some leaflets and access to a website pay lip service to consultation and is unlikely to achieve a very high level of response. Further, the initiative is held by the CNPO, an interested party providing information intended to defend proposals for new power stations. As far as we are aware there has been little attempt to analyse the responses, merely to record them. This has not prevented British Energy claiming support for the proposal based on what is, at best, anecdotal evidence. On the other hand, EDF, as successor to BE, have claimed a very low level of public response and interpreted this as a lack of public interest.

From our own observations among the Blackwater communities, we have detected a high degree of ignorance about the proposals, a condition of deep anxiety and a sense of fatalism about the inevitability of new nuclear power. There is support for the idea from some of the population who focus on the potential job benefits. There is also vociferous opposition to the proposal as the support for BANNG has shown. We believe it is impossible to conclude, on the basis of the inadequate consultation undertaken so far, that there is public acceptability for a new nuclear power station at Bradwell. Indeed, we believe there is a depth of public disquiet and opposition with many people in denial about the proposals. We would refer to Pidgeon et al’s recent study, Living with Nuclear Power (2008), carried out before the new build proposals, which portrays the multi-faceted, complex and sometimes ambiguous perspectives experienced by local people. The argument that familiarity with nuclear power makes it more acceptable may be countered by the argument that greater knowledge of the risks it poses raises public anxiety.

On the question of nuclear energy, in our response on Justification we argued that the consultation process requires greater local input, should be more proactive and more open and should encourage relevant stakeholders to participate. We reaffirm here our belief that it is in the public interest that an inquiry should be held to provide an opportunity for an open, independent and searching review of the issues involved in the decision whether to justify new nuclear power stations.

The consultation on siting strategy undertaken so far simply does not provide the evidence necessary to make a judgement on public acceptability. We believe an in-depth, wide-ranging and inclusive process of consultation and engagement is necessary in order to reach any judgement on public responses and attitudes to the siting proposals. We therefore urge a process of open and deliberative engagement with local communities enabling them to participate more fully in any siting process.

This would require government to open up its own deliberations on siting. Despite claims to openness it is clear that the siting criteria were drawn up within government advised by some experts. The criteria attracted considerable response and criticism with proposals for change. These critical responses were not openly considered by government but dealt with internally. BANNG was most dismayed that no opportunity was offered to discuss our concerns. The government’s published response basically defended the original criteria with a few minor modifications. Some of our objections were acknowledged but dismissed while others, notably our detailed response on demographics, were totally ignored.

As we have stated above, BANNG is concerned about the ‘Have Your Say’ consultation. As with previous consultations it relies heavily on willingness to respond. It is insufficient to invite responses via a website, some advertisements and leaflet distribution. In the case of the Bradwell site, leaflets have been distributed to all homes on Mersea Island (possibly as a response to efforts by BANNG to raise public awareness) but, as far as we know, this has not been extended to other parts of the local area including Colchester, a town of over 100,000 within ten miles of Bradwell. Moreover, the leaflet itself provides a very partial and one-sided account of the proposals emphasising the presumed need for nuclear energy and ignoring altogether the risks that are involved. This can only be described as a highly tendentious document using such leading questions as: ‘Why do nuclear power stations have a role to play?’ The statement that ‘sites near existing nuclear facilities are the best’ is asserted unequivocally. BANNG regards this consultation as an inadequate way to proceed and urges government to use this present ‘Have Your Say’ consultation to open up dialogue with local groups to explain how decisions on whether or not to list individual sites are reached.

3. Bradwell – the need for open and explicit information on what is really

being proposed

Power Station and Radioactive Waste Facility. The emphasis of the proposals for Bradwell and other nominated sites is on new nuclear power stations. In fact, the proposals also include radioactive waste management facilities in the form of storage buildings, spent fuel ponds, processing and encapsulation plants. We believe it is disingenuous to focus on the presumed benefits from generation of nuclear energy and fail to give sufficient emphasis to the detriments that arise from hosting long-term waste management facilities. We can only conclude that this is a deliberate policy on the part of government and nuclear operators who recognise that whereas there may be some support for nuclear energy among the population, polls consistently report overwhelming concern about radioactive waste. We therefore urge that in future public communications and consultations about new nuclear build at Bradwell the project is presented as both a new power station and a long-term radioactive waste and spent fuel store.

Lack of a solution for radioactive waste. The lack of a solution for the long term management of solid highly active radioactive wastes is a major problem. BANNG believes it is a sufficient reason to rule out the development of new nuclear stations. Since the sites for new build will host spent fuel and other wastes we consider the government should spell out the situation with respect to long term management. At the present time there is a process for seeking host sites for a possible deep disposal facility for legacy wastes based on the recommendations of the Committee on Radioactive Waste Management (CoRWM, 2006). The process is based on the willingness of potential host communities to participate. So far, only expressions of interest have been offered, all from councils in Cumbria. There is no community yet identified, let alone participating in a process of site selection. It is likely that wastes will remain in interim storage for an undefined period. Moreover, there is no process at all for wastes from new build so, in effect, sites for new build power stations will have radioactive wastes thrust upon them which are likely to remain there indefinitely. We therefore propose that government indicates the lack of a solution for the long term management of new build wastes and that it introduces a voluntary process so that communities may decide whether they wish to host the long-term management of spent fuel and other wastes at the sites of new nuclear power stations.

Number of New Stations. There is some confusion, at least in the public’s mind, about what precisely is intended at the Bradwell site. The British Energy consultation was on the basis of one new station to the east and adjacent to the former Magnox station. It was further indicated that EDF under European competition rules would have to relinquish the site but would not do so until approval was given to develop two new stations at Sizewell. Since then the NDA have auctioned their substantial land asset surrounding both Bradwell sites and it has been purchased by EDF. We understand that it is intended to sell this land on presumably to another nuclear operator. It was understood that development at Bradwell would be limited to one new station and that cooling water availability in the shallow Blackwater estuary precluded any further development. However, the large area of land now available and in the hands of EDF or a successor body suggests the possibility of more ambitious plans. This possibility appears to be confirmed in a letter on SSA nomination from the Spanish nuclear operator Iberdrola, presumably a potential purchaser, which states: ‘We consider that the Bradwell Land, as described in the draft nomination we have seen, is sufficient for at least two or three nuclear power generating units (depending on their size), together with any cooling towers which might be required either instead of, or in order to supplement any direct cooling’ (letter to DECC, 23 March, 2009).

Consultation has been on the basis of one unit. When questioned British Energy/EDF have indicated that cooling water capacity is limited and that, consequently, it would be highly unlikely for more than one station to be built. The possibility of cooling towers has also been downplayed. Iberdrola’s letter indicates that the public may have been misled and that there has been active consideration of the possibility of up to three power stations at Bradwell. BANNG considers the site unsuitable for even one new station and is alarmed that more may be contemplated. BANNG requests that the government declare openly and without equivocation or qualification that any proposals for new nuclear power at Bradwell will be limited to one station as indicated during the public consultation exercise undertaken by British Energy.

4. Bradwell – why the site is unsuitable for a new nuclear power station and radioactive waste storage facilities

In its earlier response BANNG has provided a critique of the SSA criteria. We stand by our criticisms and reaffirm them here. Our basic position as stated in our response on Justification is that siting new nuclear power stations and high active waste stores in sites liable to inundation cannot be justified in any circumstances.

In this preliminary response on siting a new station at Bradwell we focus on those issues which we consider make the site unsuitable for listing. These issues are: flooding and coastal processes; security and emergency planning; and impact on the marine and coastal environment. We also identify other potential detriments which also contribute to the case against Bradwell. In our response we believe we have covered all the siting criteria as well as some issues that are not covered in the suggested response form.

Flooding and Coastal Processes

In our response to the SSA criteria consultation we drew attention to specific problems with potential flooding of the Bradwell site. We noted various reports (Nirex, 2005; Thorne and Associates, 2005) indicating increasing likelihood of inundation especially as sea level rise is combined with more frequent storm surge. We noted that Bradwell is highly vulnerable to flooding especially beyond 100 years but within the period within which the site is likely to be operational in some form. We quoted a Meteorological Office survey which concludes that ‘the main risk to the coastal sites would be from storm surges that are caused by low atmospheric pressure and strong winds and can be further exacerbated by the funnelling effect created at estuaries and river mouths’ (BANNG, 2008a). Severe events caused by a combination of storm surge and high tides such as the East Coast flood of 1953 will be increasingly possible and must be taken into account. A report from Middlesex University’s Flood Hazards Centre concluded that at Bradwell a large increase in sea levels ‘would result in total inundation of the nuclear site and surrounding area’.

The most recent indications from climate scientists meeting in Copenhagen are of mean sea level rise of 1.2m. rising to 2m. by the end of the century. Some scientists have even warned of much higher levels, up to 6m. Depending on the assumptions made, predictions will vary considerably. The point is that there is a clear upward trend and a range of scenarios must be considered. Proposals for siting new nuclear power stations are likely to be based on data that inevitably become outdated. In planning to site new power stations it is necessary to take into account the most pessimistic forecasts of sea level rise and occurrence and height of storm surges. BANNG considers that government should consider and publish the implications of the most pessimistic scenarios based on the latest available forecasts on potential flooding and storm surges at the Bradwell site before listing the site as suitable for development.

Proposals for new build are based on a plant’s full lifetime. It is important to understand what this means although the information provided is opaque. Our impression is that lifetime is assumed to be 60 years of operating followed by about twenty years for removal of wastes and site clearance. There is, admittedly, a high degree of uncertainty about this. BANNG believes the full lifetime of new nuclear sites from operation to decommissioning and clean up could extend up to the end of the next century and beyond. We say this for the following reasons:

The high burn up fuel used in new nuclear plants is highly radioactive and takes longer to cool and is unlikely to be removed quickly.
There is as yet no long term management solution for high activity legacy nuclear wastes and no process for deciding how to manage wastes from new build
Decommissioning and clean up are costly activities and there is no certainty that sufficient resources will be in place to ensure early clearance of sites. In the case of the Bradwell Magnox station final clearance is unlikely until around 2140, that is about 180 years since the station was first commissioned.
If further daughter stations are built on the site the period before final clean up will lengthen still further.

All this suggests a presence on the site extending over several generations into a time where predictions both of environmental change and social stability become increasingly unreliable and uncertain. The problem of managing waste stores is likely to increase with time. As site conditions deteriorate with increased possibility of incursions by the sea there is the danger that cooling water in ponds may be released or wastes stores will suffer corrosion through chloride from the marine environment. A substantial release of radionuclides could be very problematic. Responsibility for dealing with dangerous wastes will be consigned to future generations who may lack the resources, skills or commitment to undertake the task. Given the increasing possibility that the site will be flooded and may become unmanageable it would appear to be unethical to proceed with the Bradwell site. In light of the uncertainties about the future length of occupation of the Bradwell site, BANNG invites the government to state how long it considers it may be practicable to maintain the site safely and securely and to clarify how, in its view, future generations will have the resources and skills necessary to continue to manage the site.

BANNG is concerned that the nuclear operators are presenting an overoptimistic assessment of the ability to defend the Bradwell site against the depredations of sea level rise and storm surge. In presenting its advice to Colchester Borough Council British Energy claimed the ‘design would be flood proof, even in a state of inundation’ (Colchester Borough Council, 2009, p.6). We find incredible the notion that a flooded site may be deemed acceptable particularly when the operator quotes Planning Policy Statement 25 whose principal aim is ‘to avoid inappropriate development in areas at risk of flooding’. By any standards a mega nuclear power station and spent fuel store must be regarded as ‘inappropriate development’ in such circumstances.

The Bradwell site is located on the equivalent of a Flood Zone 3a (medium to high risk) and as such must satisfy the Sequential Test required by PPS25 and the additional Exception Test as essential infrastructure. This means that the developer must keep the flood risk as low as practicable and that the benefits of the development outweigh the risks from flooding. BANNG has already indicated in its response to Justification that it does not consider the benefits of nuclear energy outweigh the risks. In any case we consider the precarious location of Bradwell to render the site completely untenable. Nonetheless EDF have concluded that there is no alternative site with similar strategic advantage within the local area of lower flood risk. EDF conclude that it should be possible to demonstrate compliance with the PPS25 Sequential Test. We note the tentative expression of this conclusion and the lack of any reasoning as to why the site can possibly be justified under the terms of PPS25. Contrary to EDF we believe that PPS25 quite conclusively rules out Bradwell on grounds of flood risk as a suitable site. We ask the government to confirm our view.

In its application for nomination EDF acknowledges that the site ‘would need to be made more flood resilient to accommodate a new power station.’(section 3.1). Having considered the existing defences and the potential height of a 1 in 50 year surge estimate for year 2105 the applicant states: ‘it is reasonable to conclude, at a strategic level, that a nuclear power station within the nominated site could be protected against flood risks, including the effects of climate change, throughout the lifetime of the power station’ (ibid). It must be noted that the data are based on Meteorological forecasts for 2007 and that the period covered is only a hundred years.

In our response on the SSA criteria we suggested that an exclusionary criterion on flooding ‘should seek to rule out development of a nuclear power plant in circumstances where maximum predicted sea level rise within, say, the next 300 years, combined with storm surges would cause inundation to the plant and surrounding area’ (BANNG, 2008, pp. 8-9). In its response to consultations on the SSA the government acknowledged our concern about time scales and indicated it ‘may not be universally true’ that mitigation of flooding and coastal processes would be possible (DECC, 2009, p.40). For reasons we have stated in this and our previous responses we believe Bradwell to be a site where mitigation in the long term is not possible. BANNG has already made its position clear in its response on Justification: ‘It will prove increasingly difficult to protect nuclear facilities for the long time-scales they are likely to remain hazardous. Consequently, the location of a new fleet of nuclear power stations at coastal sites cannot be justified’ ( BANNG, 2009, p.5).

As we have already noted above, predictions of sea level rise are liable to continue to increase and the site is likely to be occupied for at least 200 years. It appears the applicant has not taken either of these eventualities into account. We recognise that government may wish to undertake its own investigation on the long term protection of the site. Accordingly, BANNG asks the government to assure the public that, before listing Bradwell as a suitable site, it is satisfied that the site can be guaranteed to be defensible for a period of up to, say, 300 years under the most extreme forecasts of sea level rise and storm surge.

In terms of the coastal processes criterion, BANNG is concerned that the hard sea defences that may be constructed to defend the Bradwell site against flooding will have a devastating effect on the neighbouring coastline and its defences. The report from the Flood Hazard Research Centre indicated that the ‘power station site could become an island in the longer term’. The coast around the Blackwater is already defended in various ways and ‘managed retreat’ is one option that has been used with varying success. A Shore Line Management Plan for Essex is shortly to go out for consultation but we understand it only takes in the period up to 2100. We consider that detailed modelling and scenario building of potential changes in the coast for at least the next 200 years under varying assumptions must be undertaken before any planning proposal for a new power station at Bradwell should be considered. We believe the work should be coordinated by relevant agencies, universities and councils including the Environment Agency, the Meteorological Office and the universities of East Anglia and Essex. BANNG would be willing to contribute its own expertise to such a study.

Security and Emergency Planning

The nuclear industry is at pains to claim that modern power stations are safer and more secure than the earlier ones. BANNG would contest this claim in three respects. First, the risks from terrorism, sea level rise and radioactive waste stored on site are much higher than previously. Second, the new stations have a much higher capacity, incorporate spent fuel ponds and consequently have a much higher level of radioactivity present on site. And, thirdly, specifically in the case of Bradwell, the population most at risk in the area close to the site is much higher than it was half a century ago when the first station was built.

BANNG recognises that the probability of a major incident at the power station is low. Indeed, safety and security must be the highest priority for nuclear operators and regulators. However, incidents of varying degree do occur at nuclear plants across the world. In the case of the first Bradwell power station a leakage from a sump went undetected for 26 years (1978-2004) and, once detected, was not revealed to the public for a further four years. At the subsequent trial of Magnox South it was agreed that the incident posed little risk to the public. However, that surely is not the point. The concern is that incidents may not be detected and, when they are, may be covered up. A culture of secrecy has been endemic throughout the history the nuclear industry in the UK and elsewhere, under public or private ownership, and there is little evidence to suggest that it may change under new operators.

Nuclear operations pose a low probability/high consequence type of risk. The public may recognise a major incident is unlikely to happen but they also fear the catastrophic consequences over a considerable area that might ensue if it does. In siting new nuclear power stations risk may be mitigated in three ways. One is to minimise the risk in terms of the population exposed, two is to ensure that emergency planning procedures cover the whole population most at risk and the third is to eliminate the risk altogether.

In our response to the SSA criteria consultation we commented that the demographics criterion was confusing, unclear and unacceptable. The chosen criterion, based on population weighted by distance, is described as ‘semi-urban’, that is, it is neither ‘remote’ nor ‘urban’ but something in between. While it is not deemed necessary for a site to be remote it appears to be unacceptable for a power station to be located in an urban location. If that is so, on what grounds is it acceptable to put a semi-urban population at risk? A more logical position would be to say that the numbers at risk should be minimised and, therefore, BANNG urges government to apply a remote siting criterion for new nuclear power stations.

In terms of demographics Bradwell is not a remote site. As we stated in our response on SSA siting criteria: ‘Although the population immediately surrounding the plant is small, within 4km. and downwind of Bradwell there is the substantial town of West Mersea (8000 and doubling in summer) and within the 8km. zone are other substantial settlements at Brightlingsea and Tollesbury and a number of villages. Not far beyond this zone is the large town of Colchester (over 100,000) and other towns such as Clacton-on-Sea and Maldon. Moreover, this is an area of rapid population growth’ (BANNG, 2008, p.10).

Emergency planning procedures requiring coordination of emergency services, councils and other agencies are in place and cover a range of emergencies. BANNG considers these would prove inadequate in the event of a serious emergency such as reactor meltdown, release of radioactive pollution or terrorist attack on Bradwell power station. Three areas of concern may be identified.

Area of DEPZ. The present Detailed Emergency Planning Zone (DEPZ) only covers an area within 2.4km. (1.5 miles) of Bradwell power station. The town of West Mersea, immediately downwind of the station, is just outside this zone. BANNG considers the DEPZ to be quite inadequate especially in view of the heightened risks from the much higher radioactivity present on the site as outlined above. We therefore urge the government to require a larger area for the DEPZ at Bradwell which would, at least, cover the population of Mersea Island and other nearby villages on both sides of the Blackwater estuary.

Adequacy of Public Information. It is important that the public, at least those within the DEPZ, should be given necessary and appropriate information about emergency planning procedures. They need to understand what warnings will be given, what precautions should be taken and what actions they should take in the event of an emergency. It is imperative that the operator provides prompt and adequate warning of the nature of any incident likely to require emergency procedures. BANNG reiterates its recommendation in the response to the SSA criteria: it must be a requirement that appropriate and practicable procedures are put in place and that the affected public will be fully informed and understand what actions they should take in the event of an emergency. It should be emphasised that operators must be open, timely and precise in providing warnings and taking necessary actions.

Problem of Evacuating Population. We believe it will prove difficult, if not impossible to evacuate, if necessary, areas of dense population. We are particularly concerned about the difficulties of successfully evacuating Mersea Island with its resident 8000 population doubling in summer with an influx of holidaymakers. There is only one route off the island, the Strood Causeway, which floods at the highest tides making escape by land impossible. Even if the Strood is open it is likely to prove completely inadequate to deal with a mass exodus.

Under emergency conditions it is necessary that the population stays calm and obeys instructions. This may prove difficult. For instance, using the Sizewell Emergency Plan as guidance, those in insecure accommodation (i.e. campers and caravanners) would be evacuated first before attention is given to the permanent resident population. In a recent demonstration at the Strood, BANNG drew attention to the difficulties of successful evacuation of the island and Colchester Borough Council’s Strategic Oversight and Scrutiny Panel regard this an issue with ‘the potential to consider the site unsuitable’ (Colchester Borough Council, 2009, p.9). BANNG concludes that the problem of evacuating Mersea Island under any emergency planning procedures places a substantial population at risk in the event of a major incident at Bradwell and is a sufficient reason for government to reject the Bradwell site.

Impact on the Marine and Coastal Environments

Marine Environment. The site proposed for the new Bradwell nuclear power station is on the shallow Blackwater estuary. The estuary is important both ecologically and commercially. It is an important area for many fish. It is a significant nursery ground for plaice, sole, turbot, cod and bass and, in particular, for juvenile Blackwater Herring (a sub-species of the Thames Herring) which is already under threat. There is a wide variety of fish which support a thriving commercial fishing industry (see British Energy, 2008, p.28).

The estuary is also world famous for the Colchester Native Oysters which can be found across the whole of the Blackwater and the mouth of the River Colne. There is great concern that a new nuclear power station of the size and in the location proposed for Bradwell could have a devastating effect on the marine ecology of the Blackwater estuary and destroy the livelihoods of fishermen and oystermen.

The main threat will come from the thermal plume caused by cooling water intake and outflow. In terms of the abstraction volumes needed it is clear that the nuclear industry recognises that Bradwell is at the very limits of what it deems to be environmentally acceptable. Nonetheless, the industry claims that there is nowhere else on the estuary that a new station could be sited that would be viable from an engineering standpoint and have lower environmental impacts. The Environmental Scoping Report identified a number of constraints imposed by the cooling water needs. It is estimated that the intake and outflow of cooling water for a new station would be 72,000 cubic litres per second, representing 10% of the total volume of exchange water on each tide. The effect of the buoyant, oscillating cooling water plume on the estuary could be significant. According to the Scoping Report, ‘The water discharge from the proposed development will also be warmer than the surrounding waters by approximately 100C, and the plume will move in and out of the estuary with the tide, potentially influencing flows’ (British Energy, 2008, p.29). It is estimated that the temperature of the water around West Mersea would rise by 1-20C. In order to mitigate the impact the intake and outflow channels would be configured to limit thermal recirculation from the outfall to the intake.

The fear is that cooling water intake and outflow at such large volumes and high temperatures will affect the behaviour and distribution of marine species. There are several issues. One is the use of chlorine to prevent marine life sticking to inlet and outflow pipes. The bleaching effects on marine life of chlorination will depend on volumes, rate of decay and complex chemical reactions. Evidence of ‘dead areas’ devoid of marine life when the old power station was operating is suggestive. It is believed that the chlorination process can cause problems to the ecosystem of the estuary. This is an area where information is lacking and research is required into possible impacts from an operating power station in future. A second issue is the impact of fish intake screens on fish species as a result of larvae and eggs passing through the screens. Again, research is necessary on this issue. Third, is the impact of higher water temperature in the estuary. In particular, there is the concern that even a small rise of the order of 1-20C might upset the spawning conditions for the Colchester Native Oyster and could also affect the fattening process. Colchester oysters are a heritage industry and the product has an international reputation. The industry has made a recovery in recent years and is currently well established.

BANNG concludes that detailed research into the impacts on marine ecology arising from cooling water requirements of a new nuclear power station should be undertaken before the Bradwell site is further considered for listing. In particular research is needed on the effects of rises in water temperature, chlorination and fish impediment measures on the fishing and oyster industries.

BANNG is especially concerned about the future of the Colchester Native Oyster which is unique to the Blackwater estuary. We consider that the survival of this traditional industry should have priority over the development of nuclear energy in the estuary. We consider the risks to the oyster industry from a new power station cannot be entirely eliminated and is sufficient reason for the site not to be listed.

Coastal environment. The Blackwater estuary is protected by a number of international and national designations. Within its area are sites with the following designations: International – Ramsar Site (wetlands), Special Protection Areas (EC Birds Directive), Special Areas of Conservation (EC Habitats Directive), Essex Estuaries Marine Site; National – SSSIs, National Nature Reserve; Local – Local Nature Reserve, Coastal Protection Belt. Together these constitute significant areas of habitat for fauna and flora. The Environmental Scoping Report prepared for British Energy describes the importance of the area as follows:

‘The Blackwater Estuary..is one of the largest in Essex and recognised as being of importance for wildlife and nature conservation purposes. The Estuary supports internationally and nationally important numbers of waterfowl which predominantly occur during winter and passage periods. The surrounding intertidal and terrestrial habitats, the sea wall, ancient grazing marsh and its associated fleet and ditch systems, plus semi-improved grassland, are also of high conservation interest’ (British Energy, 2008, p.23).

The diversity of habitats supports a wide range of birds including raptors, geese, ducks and waders. The mudflats, saltmarsh, grazing marsh, sand and shingle and reed beds provide a rich ecology including some rare species of international importance. They also play an important part in sea defence. It is important to recognise the ecological interdependence of coastal habitats, including intertidal areas. These are constantly changing and overall constitute environments rich and diverse but also fragile and vulnerable. Although considerable work has been done to try to protect and preserve these areas, more research is needed on the nature of the habitats and the life they support and on the dynamics of change.

The construction and operation of a large nuclear power station will create considerable intrusion and adverse environmental consequences. The impacts will arise from displacement, noise, light pollution, construction of cooling water culverts and possibly cooling towers and, during the operational life of the station from any impacts on the coastline caused by the need to defend the site. There is also the possibility of transfer of radionuclides to the food chain through wind, bird movements or other processes. The Scoping Report points out that a new station might have a wide impact owing to its location within a network of habitats and the potential effects on birds and animal species moving between designated areas. The Report also advises that alternative solutions should be considered, including a no development option, if assessment demonstrates the works would adversely affect the integrity of a European site (ibid, p.15). In our response to the SSA criteria consultation we suggested there should be a presumption against siting new nuclear power stations within or close to designated areas. That remains our view.

BANNG considers that research is needed into the potential harm from the development and operation of a new power station and waste stores at Bradwell to ecology and environments and especially to designated areas around the Blackwater.

In view of the ecological and environmental importance of the Blackwater estuary and the need for its continued protection BANNG concludes a new nuclear power station should not be built on the Bradwell site.

Other Issues

In this response we wish to draw attention to other issues which we think also contribute to the case against the development of new build on the Bradwell site. These issues are: amenity and landscape considerations; economic impacts; and health effects.

Amenity and Landscape

Nuclear power stations impose a considerable presence on the scene and adversely impact on landscape, amenity and cultural heritage. During construction of such a large industrial complex there will be the impact of noise, light pollution, increased transportation of materials, building of transmission towers and the visual impact of buildings, cranes and operating machinery. During operation the visual impact, light pollution and transportation requirements will remain. And, during the period of decommissioning and clean up there will be demolition, waste management on site and various construction activities. Once building commences the local communities will experience a continuing detrimental impact for a period possibly spanning two centuries.

As we said in our SSA response: ‘In the case of Bradwell a new power station would stand beside the hulk of the previous one creating a substantial industrial complex in a rural area on an estuary used for fishing, sailing and passive recreation. The complex would be close to the 7th century St. Peter’s Chapel, one of the oldest and most important Christian buildings in the country. A survey by Ipsos-Mori found that the population in the area overwhelmingly favoured returning the site to its natural state’ (BANNG, 2008, p.12).

It is worth reiterating that Bradwell is not an operational site and that it was intended to clear the site within a relatively short period. Instead, financial constraints and technical reasons have been given as reasons for the site not being finally cleared for 125 years. In addition it is proposed to build one or more new power stations on the site thereby increasing the scale of visual and environmental impact and lengthening the period of occupation of the site. In addition to the reactor buildings and other facilities for radioactive waste, new and bigger transmission towers will be required and, depending on the number of reactors and limitations on water abstraction, it may be necessary to erect cooling towers.

BANNG is very concerned about the overall impact of the proposed new power station and associated infrastructures on the amenity of the Blackwater estuary. This is an area of passive recreation and attracts large numbers of campers and caravanners during the holiday season. BANNG believes that the noise from construction and the visual intrusion during construction, operation and decommissioning of any new build station, together with the presence of the old station will destroy the amenity of the tranquil and beautiful Blackwater estuary. Accordingly,

We conclude there should be a presumption against the development of new nuclear facilities at Bradwell on the grounds that it will adversely affect the existing land and water uses, amenity and cultural heritage of the Blackwater estuary.

Economic Impacts

One of the claims made in favour of new nuclear stations is the jobs they bring to a local economy. The NIA claims that there would be ‘significant social-economic benefits to the local economy resulting from a new nuclear power station’ (DECC, 2008, p.102). Each station would provide around 500 highly skilled, long term, well paid and stable jobs which would be ‘especially valuable in the remote communities that host nuclear power stations’ (p.102). These claims bear critical examination. It is unclear why the jobs would be especially valuable in a rural area than in, say, a declining industrial area. Nor, if development here is necessary at all, is it clear that nuclear is necessarily the only alternative source of employment; other energy developments might also provide a source of continuing jobs. It might be argued that introducing new nuclear in a rural area could create an economy with an unhealthy dependence on one employer.

In any case the NIA emphasises only the employment benefits; it is silent on the possibility of economic detriments. As we argued in our response on Justification the association of nuclear energy with radioactive risk tends to create a negative image and anxiety among the population surrounding nuclear plants. This image is likely to be compounded in the case of new build projects which include spent fuel and waste stores. This may act as a deterrent to inward investment, impact negatively on existing economic activities and create a blighting effect.

In addition to these impacts, as we have stated earlier in this response, the Bradwell proposal might have a direct detrimental effect on the fishing and oyster industries of the Blackwater and neighbouring Colne estuaries. That is one of the reasons why we are vehemently opposed to the project. We consider it is not sufficient simply to assert the benefits of job creation; it is necessary to undertake appropriate research to determine the overall potential economic benefits and detriments. We reiterate the conclusion we reached in our Justification response:

BANNG considers the economic detriments over the long-term likely to be experienced by the local communities surrounding new nuclear power stations and waste storage facilities must be taken into account in assessing the economic impact of new build at specific sites.

Health Effects

In our response to the SSA criteria consultation we suggested that an additional criterion on Health Effects should be included. Following the SEA Objectives 6 and 7 set out in the Environmental Study (BERR, 2008, p.35) we suggested a health criterion should be phrased ‘in terms of operators demonstrating through independent research that any new power station development will not be significantly detrimental to the mental or physical health of people living in the vicinity during the whole period of operations and subsequent clean-up’ (BANNG, 2008, p.13). In its response to this suggestion the Government indicated that potential health effects would be considered in the Appraisal of Sustainability and were fundamental to the Justification process (DECC, 2009, p.47).

BANNG recognises that health impacts are a significant generic issue but we also consider there are local implications that need to be carefully considered in respect of individual sites. Health may be prejudiced by the release of radionuclides to the accessible environment through routine or accidental emissions and discharges to air, land and water. Radiation health is a problematic area and, as the Nuclear Consultation Working Group (2008), now the Nuclear Consultation Group (NCG), has pointed out there was no attempt at a coherent discussion of radiation health effects during the government consultation on nuclear energy. However, there is sufficient evidence of health detriments near nuclear facilities to indicate a cause for concern. As the NCG has pointed out there is an acknowledged, statistically significant excess of childhood leukaemias in the vicinity of the Sellafield reprocessing plant and a similarly elevated rate near Dounreay (NCG, 2009). There have been indications of elevated childhood leukaemia clusters elsewhere. A recent German study discovered that risk of tumour or leukaemia in children under 5 significantly increases the closer they live to a nuclear power plant (Kaatsch et al, 2008). There are also concerns from research on genomic instability which suggest that radiation health effects are potentially far more widespread and risks arise after exposure to doses far lower than current safely limits allow. Concerns have also been raised about the potential effects of tritium that is routinely released to air and sea from nuclear power plants. It is also the case that various reports (notably by COMARE) have argued that excess cancers in local populations cannot be attributed to exposure to radioactive emissions from nuclear facilities.

There have been some investigations in the Blackwater area where statistical analysis has suggested excess cancers and higher breast cancer mortality arising from the formerly operating power station at Bradwell (Busby and Bramhall, 2002). Findings such as these are questioned and controversial. More recently, there has been reworking of data on childhood leukaemias in the Blackwater area following the German study which indicates a possibility of higher levels than in the populatin at large. There has also been discussion about the discrepancies in data on malignant neoplasms in the area surrounding the Bradwell plant reported to Colchester Borough Council and which will be subject to further consideration (Colchester Borough Council, 2009). All that may be said is that the evidence is suggestive but not conclusive. Even when correlation between nuclear facility and cancer levels can be demonstrated it does not necessarily confirm causation.

This is not the place to interrogate this complex and controversial area. However, the possibility that local populations may be at higher risk of some cancers as a result of proximity to nuclear facilities than the population as a whole is an important issue. It is particularly so where there is a substantial population in the vicinity of the plant as is the case for Bradwell where the substantial settlements of West Mersea, Tollesbury and other villages are within 5km. of the plant. Although the evidence of harm is not conclusive the possibility that it may be caused by proximity to the plant indicates the precautionary principle should apply, i.e. the absence of conclusive evidence should not be used to justify the development of a potentially hazardous activity. This conclusion reinforces the need for a remoteness criterion to be applied to the siting of new nuclear power stations, as suggested earlier in this response

BANNG considers the potential health risk to the substantial population in the area around the Bradwell site is sufficient reason for the site to be excluded from further consideration for a new nuclear power station.

5. Conclusion

In this response we have emphasised a number of specific reasons why we believe Bradwell is an inadequate and unacceptable site for the development of a new nucler power station and radioactive waste facilities. We are especially concerned about the vulnerability of the site to flooding, the problems of safely evacuating a large population in the case of a major emergency, the harm to marine and coastal environments, the potential loss of a unique and famous oyster industry, the blight, disturbance and visual offence that would be delivered to a peaceful and beautiful environment and the risk to health of the substantial population exposed to routine or accidental discharges and emissions from the plant.

BANNG is also concerned about the inadequacy of the consultation process undertaken so far. It appears the procedure has been designed primarily for people who are familiar with electronic forms of communication. The website is quite difficult to navigate. The response form is directive requiring answers on specific criteria which are not defined for the respondent. It is unclear what will happen to the responses beyond going into a ‘black hole’ to be dealt with by some mysterious and closed process. If the process is to have any credibility or achieve any public trust and acceptability it must be opened up to scrutiny by those who have taken the trouble to respond. It is insufficient merely to publish all responses on the website. BANNG requests that, before any sites are formally listed, the government will engage in dialogue with respondents. We consider it is necessary for government openly to state, debate and justify the conclusions that it reaches in respect of each specific site that it intends to list.

Prepared by Professor Andrew Blowers, OBE, Chair, on behalf of the Blackwater Against New Nuclear Group

May 14 2009

References

BANNG (2008) Consultation on the Strategic Siting Assessment Process and Siting Criteria for New Nuclear Power Stations in the UK: Response to the Consultation on Behalf of the Blackwater Against \New Nuclear Group (BANNG), November 9

BANNG (2009) 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 the Blackwater Against New Nuclear Group (BANNG), March 19

BERR (2008) Towards a National Policy Statement: Consultation on the Strategic Siting Assessment Process and Siting Criteria for New Nuclear Power Stations in the UK, July

British Energy (2008), Proposed Nuclear Development at Bradwell: Environmental Scoping Report, Royal Haskoning UK, November

Busby, C. and Bramhall, R. (2002) ‘Breast cancer mortality and proximity to Bradwell Nuclear Power Station in Essex 1995-1999. Correction and Update to 2001 with a commentary on Official Responses’, Green Audit: Aberystwyth, Occasional Paper 2002/6, December

Colchester Borough Council (2009) Strategic Overview and Scrutiny Task and Finish Group: A New Build Power Station at Bradwell

Committee on Radioactive Waste management (CoRWM)(2006) Managing Our Radioactive Waste Safely: CoRWM’s Recommendations to Government, November

DECC (2009) Towards a National Nuclear Policy Statement: Government response to consultations on the Strategic Siting Assessment process and siting criteria for new nuclear power stations in the UK; and to the study on the potential environmental and sustainability effects of applying the criteria, Office for Nuclear Development, January

P. Kaatsch, C. Spix, R. Schulze-Rath, S. Schmeidel and M. Blettner: ‘Leukaemia in young children living in the vicinity of German nuclear power plants’. International

Journal of Cancer, 2008, Vol. 122 (4), 15 Feb., 72

Nirex (2005) ‘The impact of rising sea levels on coastal sites with radioactive waste stores’ UK Nirex Ltd., Technical Note 484385, September

Nuclear Consultation Group (2009) Consultation on the Nuclear Industry Association’s Application to Justify New Nuclear Power Stations: Response from the Nuclear Consultation Group (NCG)

Nuclear Consultation Working Group (2008) Nuclear Consultation: Public Trust in Government

Pidgeon, N., Henwood, K., Parkhill, K., Venables, D. and Simmons, P. (2008) Living with Nuclear Power in Britain: A Mixed-methods Study, Cardiff University and University of East Anglia. ESRC Social Contexts and Responses to Risk (SCARR) Research Report, School of Psychology, Cardiff

Thorne and Associates (2005) ‘Understanding of Climate and Landscape Change to support Optioneering at NDA Sites: Phase 2’, March

APPENDIX 1

SUMMARY OF RECOMMENDATIONS

1. Nature of the Response

BANNG wishes that all three responses to consultations it has made (on SSA criteria, on Justification and this response) to be taken into account by government when considering the suitability of the site for listing in the draft Nuclear National Policy Statement.

BANNG considers much more time and support should be given for Citizens’ Based Organisations and other interested parties to make a full and considered response to the siting proposals.

BANNG considers the method of response indicated by government to be inhibiting and inflexible and likely to limit the issues considered.

We, therefore, urge the government to reject the site. However, if it is decided to list the site we request that the reasons for its acceptance are set out along with the reasons why the objections by us and others have been rejected.

2. Concerns about the Consultation Process so far

We reaffirm here our belief that it is in the public interest that an inquiry should be held to provide an opportunity for an open, independent and searching review of the issues involved in the decision whether to justify new nuclear power stations.

We therefore urge a process of open and deliberative engagement with local communities enabling them to participate more fully in any siting process.

BANNG regards this consultation as an inadequate way to proceed and urges government to use this present ‘Have Your Say’ consultation to open up dialogue with local groups to explain how decisions on whether or not to list individual sites are reached.

3. Bradwell – the need for open and explicit information on what is really being proposed

We urge that in future public communications and consultations about new nuclear build at Bradwell the project is presented as both a new power station and a long-term radioactive waste and spent fuel store.

We propose that government indicates the lack of a solution for the long term management of new build wastes and that it introduces a voluntary process so that communities may decide whether they wish to host the long-term management of spent fuel and other wastes at the sites of new nuclear power stations.

BANNG requests that the government declare openly and without equivocation or qualification that any proposals for new nuclear power at Bradwell will be limited to one station as indicated during the public consultation exercise undertaken by British Energy.

4. Bradwell – why the site is unsuitable for a new nuclear power station and radioactive waste storage facilities

Flooding

BANNG considers that government should consider and publish the implications of the most pessimistic scenarios based on the latest available forecasts on potential flooding and storm surges at the Bradwell site before listing the site as suitable for development.

BANNG invites the government to state how long it considers it may be practicable to maintain the site safely and securely and to clarify how, in its view, future generations will have the resources and skills necessary to continue to manage the site.

Contrary to EDF we believe that PPS25 quite conclusively rules out Bradwell on grounds of flood risk as a suitable site. We ask the government to confirm our view.

BANNG asks the government to assure the public that, before listing Bradwell as a suitable site, it is satisfied that the site can be guaranteed to be defensible for a period of up to, say, 300 years under the most extreme forecasts of sea level rise and storm surge.

We consider that detailed modelling and scenario building of potential changes in the coast for at least the next 200 years under varying assumptions must be undertaken before any planning proposal for a new power station at Bradwell should be considered.

Security and Emergency Planning.

BANNG urges government to apply a remote siting criterion for new nuclear power stations.

We urge the government to require a larger area for the DEPZ at Bradwell which would, at least, cover the population of Mersea Island and other nearby villages on both sides of the Blackwater estuary.

It must be a requirement that appropriate and practicable emergency procedures are put in place and that the affected public will be fully informed and understand what actions they should take in the event of an emergency. It should be emphasised that operators must be open, timely and precise in providing warnings and taking necessary actions.

BANNG concludes that the problem of evacuating Mersea Island under any emergency planning procedures places a substantial population at risk in the event of a major incident at Bradwell and is a sufficient reason for government to reject the Bradwell site.

Impact on the marine and coastal environment

BANNG concludes that detailed research into the impacts on marine ecology arising from cooling water requirements of a new nuclear power station should be undertaken before the Bradwell site is further considered for listing. In particular, research is needed on the effects of rises in water temperature, chlorination and fish impediment measures on the fishing and oyster industries.

Other Issues

APPENDIX 2

Blackwater Against New Nuclear Group (BANNG)

Aims and Strategy

Aims and Purpose

The purpose of the Group is 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.

To this end the Group has five broad aims:

to raise public awareness among the Blackwater communities of the potential consequences for health, environment and safety of proposals for new nuclear development;
to identify key issues of concern and to gather credible and responsible research and information to pursue the case against nuclear development;
to challenge any proposals for future nuclear power at the Bradwell site by presenting robust evidence and arguments to local and national decision makers, regulatory bodies, the nuclear industry, non government organisations, the media and the general public;
to support the early and successful decommissioning and clean up of the existing Bradwell nuclear site as an integral element of the long-term protection and conservation of the Blackwater estuary;
to call for an open, transparent and deliberative decision making process in which local communities are afforded full access to all information and involvement in key decisions affecting them.

Strategy

In pursuit of these aims the Group will develop a strategy with the following components:

1. Information and research

Gathering all available relevant research and evidence on key issues and disseminating it throughout the local communities. This may involve developing a data bank and associated web site.

Liaison and communication with national expert groups (e. g. Nuclear Consultation Working Group, Nuclear Waste Advisory Associates) to ensure relevant expertise is readily available.

Identifying uncertainties and gaps in knowledge and initiating or urging further research.

Encouraging accessible and intelligible information on monitoring of air, water and soil quality in the Blackwater estuary.

2. Raising Public Awareness

Deepening awareness by reaching out to the whole community through leaflets, posters, local media and key local organisations.

Broadening awareness by reaching neighbouring communities around the Blackwater estuary and the surrounding areas including major centres such as Colchester, Maldon and Clacton.

Involving local people through public meetings, petitions, lobbying and other activities.

3. Decision Making

Communicating community concerns to decision makers at local and national levels, including, government ministers, local MPs, County, Borough and Town/Parish Councils.

Ensuring community concerns are fully considered at every stage in decision making, including, environmental appraisal, impact assessment, reactor design, waste management proposals, planning considerations and application.

Ensuring regulatory authorities fully consider those issues specifically relating to health and environmental impacts of a power station at the Bradwell site.

Urging the full implementation of all plans, policies, directives and other programmes that are aimed at the protection and enhancement of the Blackwater estuary.

Working in an open and transparent manner and encouraging other decision makers to act in the same way.

Organisation, Administration and Finance

The Group will be participative and democratic in principle and practice.

Key decisions on strategy will be taken by supporters at open meetings.

A small core group (executive) will be responsible for day-to-day organisation and decision making, referring key decisions to the open meeting.

Sub-groups will undertake specific tasks and functions.

There is a Chair, Secretary, Treasurer, Media Relations Officer, Community Awareness Co-ordinator and Strategy Co-ordinator.

Fund-raising will be undertaken.