The Rt. Hon. Edward Davey, MP,
Secretary of State for Energy and Climate Change,
Department of Energy and Climate Change
Dear Mr. Davey
I am writing to you about the proposal by the Nuclear Decommissioning Authority (NDA) to dissolve fuel element debris (FED) at Bradwell, which will result in aqueous discharges of radionuclides, nitrates and heavy metals into the Blackwater estuary. This proposal is causing some alarm.
I am also writing in a similar vein to the Secretary of State for the Environment.
This is an urgent issue as the dissolution has been delayed and my group, the Blackwater Against New Nuclear Group (BANNG), which is based in West Mersea 2 miles over the estuary from Bradwell, is asking you formally to have the discharges stopped.
I should like to point out that BANNG is opposed to aqueous discharges from FED dissolution into UK coastal waters from any nuclear site 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.
If the discharges at Bradwell do go ahead, it is understood that they will be carried out twice a day for a year and a half.
The NDA claims that dissolution of FED reduces its volume by a factor of 20, whilst retaining ‘more than 85% of the radioactivity in residues that will be managed along with other ILW wastes at the site’. The reduction in volumes results in less storage space being required for Intermediate Level Waste (ILW) but ‘it does lead to some discharges of radioactive and non-radioactive by-products to the environment’. (NDA Credible Options paper for Optimising FED Treatment (Dissolution) Facilities, May, 2013, pp. 3 and 4)
It is evident that the Environment Agency 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, May, 2013, p. 10)
BANNG believes that the Environment Agency may have granted the permit to Magnox South to proceed with FED dissolution at Bradwell before any stakeholder consultation took place and before the decision to designate the estuary as a Marine Conservation Zone. The little public consultation that has taken place has been limited and after decisions were taken.
It should be noted that the tidal refresh rate for the Blackwater estuary is ten days. This means that much of the contaminated water will return on the following tide and the discharges will take a long time to disperse. There is also the effect of the high salinity, which may act to retain and concentrate discharges.
BANNG has written to the NDA on three occasions since October, 2013 to ask what the proposed discharges will contain and is still awaiting a detailed response.
At the present time, work is being undertaken to remove a very large amount of silt (around 1,400 tonnes, we believe) from the disused cooling ducts of the former Bradwell nuclear power station. It is understood that new, smaller bore pipes will then be inserted into one of these for the FED discharges.
There is uncertainty as to whether the silt contains biocide and radioactivity. The silt will be disposed of in the estuary. We believe that the local oystermen and fishermen have already expressed their fears to the local MP, Bernard Jenkin, about the effects of this on the marine life and on the Colchester Native Oyster, particularly about any effects on the oyster’s spawning season.
BANNG shares the fears of the Mersea oystermen and fishermen regarding the effects of the removal of silt on the marine life of the Blackwater, in particular on the Colchester Native Oyster, an important element of the local economy.
Given the uncertainties, the lack of the information and the possible impacts, it would seem to be irresponsible if the discharges of radioactivity, nitrates and heavy metals were to proceed. BANNG believes that they should be stopped and that the delays now being experienced provide an opportunity to do so.
As you will be aware, the Blackwater estuary was recently designated as part of a Marine Conservation Zone (along with the Rivers Crouch, Roach and Colne). This is surely an acknowledgement of the importance of the environment of the estuary. The planned discharges and disposal of silt seem to repudiate this designation, which is supposed to provide added protection to marine life in the estuary and to ensure specific protection for the Colchester Native Oyster.
We also believe that the discharges are in contravention of the OSPAR Convention which seeks to reduce discharges to ‘close to zero’ by 2020.
Our detailed opposition is spelled out in the attached response (BANNG Paper No. 24) to the NDA’s paper for comment on its Preferred Choice for Optimising the Number and Location of Interim Level Waste (ILW) Storage Facilities on Magnox Limited and EDF Energy Sites; and FED Treatment (Dissolution) Facilities in Magnox Limited (November, 2013).
BANNG would ask you to investigate urgently the issues raised. We look forward to hearing the results of your investigations and, in particular, answers to the questions that follow that we have put to the NDA.
- 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 set out in this letter, BANNG is formally asking you to stop the discharge of any pollutants into the precious and fragile Blackwater estuary.
I look forward to hearing from you. It would be appreciated if you would send a copy your response by e-mail.
Blackwater Against New Nuclear Group (BANNG)
The Baroness Verma, Minister for Energy and Climate Change
Rt. Hon. Bernard Jenkin, MP
Rt. Hon. John Whittingdale, MP
Rt. Hon. Douglas Carswell, MP
Rt. Hon. Sir Bob Russell, MP
Vicky Ford, MEP
Richard Howitt, MEP
Maldon District Council
Colchester Borough Council
West Mersea Town Council
Essex County Council
Nuclear Decommissionng Authority
Marine Management Organisation
Chair, Bradwell Local Community Liaison Committee