Mr. John Clarke,
Nuclear Decommissioning Authority
Dear Mr. Clarke,
Proposed Aqueous Disharges from FED Dissolution at Bradwell
I am writing to you on behalf of the Blackwater Against New Nuclear Group (BANNG) to request you formally not to proceed with the proposed aqueous disharges containing radionuclides, nitrates and heavy metals into the Blackwater estuary from the experimental FED dissolution plant at Bradwell.
I wish to make it clear that BANNG opposes such discharges from any nuclear site into UK coastal waters but is particularly concerned at those proposed for the Blackwater. We believe that FED should not be dissolved but packaged and stored, as e.g. at Hunterston A.
BANNG’s detailed opposition to the proposed aqueous discharges is spelled out in the attached response submitted to you in relation to your paper for comment on the NDA’s Preferred Option to ILW Storage and FED Treatment (Dissolution) Facilities (November, 2013).
It is evident that the Environment Agency (EA) considers these discharges to be at the very limits of what the Blackwater estuary can safely tolerate, as the Agency has given permission for the new Bradwell dissolution plant to be for single use only and not as a shared plant:
‘whilst the short-term impacts of discharges have been deemed acceptable……the Bradwell site is sub-optimal in terms of longer term environmental impacts, as would occur if Bradwell was used as a shared plant’. (NDA Credible Options paper for Optimising FED Treatment (Dissolution) Facilities, May, 2013, p. 10)
BANNG is concerned that the permit for the FED dissolution plant at Bradwell may have been granted before any stakeholder consultation took place and before the designation of Marine Conservaton Zone was considered. Is that correct? The little public consultation that has taken place has been limited and after decisions have been made.
BANNG understands that currently work on cleaning out silt from the cooling water ducts of the former power station, necessary to allow the insertion of smaller bore pipes to take the discharges, is behind schedule. We believe that this provides the opportunity to stop the discharges before they begin.
We understand that the silt may contain radioactivity and biocide. It is proposed to dispose of hundreds of tons of this silt in the estuary. As this is in addition to polluting the estuary with FED discharges, it seems a further reason to stop FED dissolution at Bradwell.
As you are aware, in December, 2013, the Blackwater estuary was created a Marine Conservation Zone. Such a designation recognises the environmental importance of the estuary and affords specific protection for the Colchester Native Oyster. It adds to the many national and international environmental designations already awarded. BANNG believes that the proposed discharges and disposal of hundreds of tons of silt into the estuary are a repudiation of the Marine Conservation Zone designation. We also believe that they contravene the OSPAR Treaty, which seeks to reduce discharges to close to zero by 2020.
The Vice Chair of BANNG has written three times to you to ask what the constituents of the discharges will be and still awaits a detailed response. We understand that the discharges will include radionuclides, nitrates and heavy metals.
We would ask you to respond urgently to the questions that follow.
- Was the long tidal refresh rate of the Blackwater estuary taken into account when decisions were made to dissolve FED at Bradwell and to discharge radioactivity and other pollutants into the estuary?
- What radionuclides, heavy metals and other pollutants will be present in the aqueous discharges?
- Are radioactivity, biocide and other pollutants present in the silt? If so, how will they be dealt with?
- What are the risk probabilities for harm from the discharges to the marine life, including the Colchester Native Oyster, in the Blackwater estuary and how might these vary according to the volume and rates of the discharges and to tidal flow variations?
- A substantial number of people use the estuary for leisure activities, e.g. swimming, yachting, dinghy sailing, windsurfing, kayaking, etc. which often take place within metres of the proposed discharge outlets (including sailing lessons for children). What are the risk probabilities for harm to them from the discharges and how might the risks vary according to the volume and rates of the discharges and to tidal flow variations?
- Do you accept that the discharges and the dumping of silt compromise the Blackwater’s new designation as a Marine Conservation Zone as well as its other national and international environmental designations?
- Do you accept that the discharges and the dumping of silt contravene the OSPAR Convention?
- Will the delays in removing silt from the disused cooling ducts at the former nuclear station have the effect of delaying the entry of Bradwell into Care and Maintenance status?
For all the reasons given above, BANNG believes that FED dissolution should not take place at Bradwell
I look forward to hearing from you. It would be appreciated if you would send me a copy of your response by e-mail.
Secretary & Media Relations Officer,
Blackwater Against New Nuclear Group (BANNG)
Rt. Hon. Bernard Jenkin, MP
Rt. Hon. John Whittingdale, MP
Rt. Hon. Douglas Carswell, MP
Rt. Hon. Bob Russell, MP
Vicky Ford, MEP
Richard Howitt, MEP
Maldon District Council
Colchester Borough Council
West Mersea Town Council
Essex County Council
Marine Management Organisation
Chair, Bradwell Local Community Liaison Committee