BANNG has taken the unusual initiative of seeking direct talks with the Chinese state-owned nuclear companies who are considering developing their own nuclear power stations at the Bradwell site. BANNG’s Chair, Professor Andy Blowers, has written to the heads of the China National Nuclear Corporation and the China General Nuclear Power Group pointing out the formidable obstacles, some of them possibly insurmountable, that would have to be overcome before new nuclear power could be brought to Bradwell.
‘We know that the government has said it welcomes Chinese investment in the UK’s strategic infrastructure. We also know that EDF, the French government-owned nuclear company, is in negotiations with a view to transferring its Bradwell site to the two Chinese state-owned companies. Before this transaction goes any further we think the Chinese should be warned about the serious technical, environmental and political difficulties they would face in building on the Blackwater estuary’.
In his letters to the Chinese Prof. Blowers emphasises the scale of local opposition the project is likely to encounter. He points out that BANNG gathered 10,000 signatures in a face-to-face petition against new nuclear development at Bradwell which, he observes, ‘must surely be one of the most conclusive surveys of public opinion at any of the sites proposed for new nuclear stations in the UK’.
The former power station is now redundant and will soon be mothballed as a nuclear waste site. New nuclear reactors together with highly active nuclear waste stores and possibly cooling towers would represent a violent tranformation of a tranquil haven of recreation into a polluted and dangerous industrial zone.
Major issues of public concern
Three issues concern the public most of all. One, is the potential health risks from radioactivity, a controversial issue but one on which it is generally accepted that nuclear activities present a risk difficult to calculate but present nonetheless.
Second are the concerns about the possibility of a major incident, accidentally or deliberately created, resulting in devastating consequences for a substantial population as far afield as towns like Colchester, Chelmsford, Clacton and Southend-on-Sea. As Prof, Blowers says, ‘History shows that major nuclear accidents can have global impact, a nuclear accident somewhere is a nuclear accident everywhere’.
And, thirdly, there are the concerns about the future with highly dangerous spent fuel and highly radioactive wastes stored on site and likely to be there until the end of the next century. ‘Already Bradwell is a nuclear waste site. New nuclear development would massively increase the volumes and the radioactivity of long-lived dangerous waste on a site that will be increasingly liable to flooding vulnerable to the impacts of coastal processes, erosion and storm surges.’
There are other concerns, notably the impact of new nuclear stations on the marine ecology, fishing and the oyster industry. And there is the technical problem of supplying sufficient cooling water from a shallow estuary with a very slow refresh rate.
BANNG believes that the Chinese companies would do well to gain a deeper appreciation of the problems to be faced in developing new nuclear power at Bradwell.
Issue of conditions of land transaction
BANNG has also written in similar vein to Vincent de Rivaz, CEO of EDF Energy, owners of the Bradwell site and potential developers at Hinkley Point in Somerset and Sizewell in Suffolk. In his letter to EDF, Prof. Blowers raises the question of conditions entered into under competition rules when the site was purchased by EDF. Prof. Blowers writes:
‘As I understand it EDF is not obliged to sell the site to another operator until planning approval to build two reactors at Sizewell has been achieved. At the time this was presumably seen as providing some protection from competition for EDF. It would appear that EDF is now prepared to sell the site to a potential competitor without such restrictive conditions. I should be grateful if you can confirm this to be the case and whether this has any implications for EDF’s investment in the UK nuclear industry.’.
A possible interpretation of EDF’s possible sale of the Bradwell site to the Chinese now is that it may be losing interest in the development of its site at Sizewell.
BANNG is concerned that in the negotiations with the Chinese the disadvantages of the site and opposition to its development for nuclear purposes have been ignored or disregarded. The group is, therefore, calling for the opportunity to discuss with EDF and the Chinese companies the problems surrounding the development of the site.
LETTERS SENT TO CNNC AND CGNPG and EDF:
15 June 2015
The Chairman,
China National Nuclear Corporation
Dear Chairman,
New Nuclear Development at the Bradwell Site in Essex, England
I am writing to you in my role as Chair of the Blackwater Against New Nuclear Group (BANNG) to seek a meeting with representatives of your company to discuss the developmental problems surrounding the Bradwell site. I understand that you are at present in negotiation with EDF on the sale of this site but feel this is a most appropriate time for you to be aware of the technical, environmental and political difficulties a developer might encounter at Bradwell. I have little doubt that you will have considered some of these in reaching a conclusion on whether to pursue this project. However, I think it would be helpful if your company could gain an understanding of the problems with the site from the perspective of local communities living in the area.
Over several years BANNG has presented responses to consultations, had discussions with local councils, MPs, nuclear regulators and government and has raised public awareness of the issues concerning new build. In particular we have stressed that any development at the Bradwell site would also include the management of spent fuel and other highly active wastes up to the end of the next century. We have pointed out that the former power station at Bradwell is now redundant and that new reactors would be far larger in scale and would transform a peaceful haven of recreation into an industrial estuary.
We have published many detailed and well-researched papers and these can be found on our website (a list of these papers is attached). Among our awareness raising activities was the gathering of 10,000 signatures in a face-to-face petition opposing development at Bradwell, which was presented to the Energy Minister of HM Government. Around 80% of the citizens we contacted signed the petition, which must surely be one of the most conclusive surveys of public opinion at any of the sites proposed for new nuclear stations in the UK. I think it fair to say that the public in the communities around the Blackwater are overwhelmingly opposed to new nuclear development and the storage of dangerous wastes at the Bradwell site.
This opposition stems from a number of factors. There is, of course, the fundamental anxiety about potential health risks, a controversial issue but one on which it is generally accepted that nuclear activities present a risk difficult to calculate but present nonetheless. There are also concerns about the possibility of a major incident which could have devastating consequences for a wide surrounding area containing up to 300,000 people.
Safety and security risks apply to any new nuclear power station but there are also quite specific reasons why new nuclear should not be contemplated at Bradwell. These are, first, the problem of extracting large volumes of cooling water from a shallow estuary with a low refresh rate. This presents a technical challenge which may be insurmountable even if cooling towers or sea intake were to be contemplated. Secondly, there are issues of marine and terrestrial pollution and contamination arising from discharges and emissions into a sensitive and highly protected environment. Contemporary controversy over the discharge of fuel element debris (FED) from the former Bradwell power station indicates the kind of public concern that would be encountered. Third, is the vulnerability to flooding, storm surges and coastal processes of a low-lying coast. It is likely that power generation would continue until near the end of this century and that dangerous wastes stored on the site would have to be managed until the end of the next century in deteriorating conditions and might become unmanageable. The prospect of Bradwell effectively becoming a permanent radioactive waste store is truly worrying.
I appreciate you will have many things to consider during your negotiations on the Bradwell site, not the least of which will be the financial considerations. But, apart from whether the project is financially viable, is the question of whether the site is suitable. There are formidable obstacles to be overcome here, some of them possibly insurmountable. I hope your representatives will be prepared to meet with myself and colleagues to gain a deeper appreciation of the problems facing the development of new nuclear at the Bradwell site.
It would be appreciated if you would please e-mail your response to me as I am not always in residence at the address given above. My e-mail address is:
Andrew.blowers@open.ac.uk
I am sending a similar letter to the China General Nuclear Power Group.
Yours sincerely,
Prof. Andrew Blowers, OBE
Chair, Blackwater Against New Nuclear Group (BANNG)
Co-Chair, UK Government/NGO Nuclear Forum
Member of the first Committee on Radioactive Waste Management (CoRWM1)
Cc:
Rt.Hon. Bernard Jenkin, MP; Rt. Hon. Priti Patel, MP
15 June 2015
The Chairman,
China General Nuclear Power Group
Dear Chairman,
New Nuclear Development at the Bradwell site in Essex, England
I am writing to you in my role as Chair of the Blackwater Against New Nuclear Group (BANNG) to seek a meeting with representatives of your company to discuss the developmental problems surrounding the Bradwell site. I understand that you are at present in negotiation with EDF on the sale of this site but feel this is a most appropriate time for you to be aware of the technical, environmental and political difficulties a developer might encounter at Bradwell. I have little doubt that you will have considered some of these in reaching a conclusion on whether to pursue this project. However, I think it would be helpful if your company could gain an understanding of the problems with the site from the perspective of local communities living in the area.
Over several years BANNG has presented responses to consultations, had discussions with local councils, MPs, nuclear regulators and government and has raised public awareness of the issues concerning new build. In particular we have stressed that any development at the Bradwell site would also include the management of spent fuel and other highly active wastes up to the end of the next century. We have pointed out that the former power station at Bradwell is now redundant and that new reactors would be far larger in scale and would transform a peaceful haven of recreation into an industrial estuary.
We have published many detailed and well-researched papers and these can be found on our website (a list of these papers is attached). Among our awareness raising activities was the gathering of 10,000 signatures in a face-to-face petition opposing development at Bradwell, which was presented to the Energy Minister of HM Government. Around 80% of the citizens we contacted signed the petition, which must surely be one of the most conclusive surveys of public opinion at any of the sites proposed for new nuclear stations in the UK. I think it fair to say that the public in the communities around the Blackwater are overwhelmingly opposed to new nuclear development and the storage of dangerous wastes at the Bradwell site.
This opposition stems from a number of factors. There is, of course, the fundamental anxiety about potential health risks, a controversial issue but one on which it is generally accepted that nuclear activities present a risk difficult to calculate but present nonetheless. There are also concerns about the possibility of a major incident which could have devastating consequences for a wide surrounding area containing up to 300,000 people.
Safety and security risks apply to any new nuclear power station but there are also quite specific reasons why new nuclear should not be contemplated at Bradwell. These are, first, the problem of extracting large volumes of cooling water from a shallow estuary with a low refresh rate. This presents a technical challenge which may be insurmountable even if cooling towers or sea intake were to be contemplated. Secondly, there are issues of marine and terrestrial pollution and contamination arising from discharges and emissions into a sensitive and highly protected environment. Contemporary controversy over the discharge of fuel element debris (FED) from the former Bradwell power station indicates the kind of public concern that would be encountered. Third, is the vulnerability to flooding, storm surges and coastal processes of a low-lying coast. It is likely that power generation would continue until near the end of this century and that dangerous wastes stored on the site would have to be managed until the end of the next century in deteriorating conditions and might become unmanageable. The prospect of Bradwell effectively becoming a permanent radioactive waste store is truly worrying.
I appreciate you will have many things to consider during your negotiations on the Bradwell site, not the least of which will be the financial considerations. But, apart from whether the project is financially viable, is the question of whether the site is suitable. There are formidable obstacles to be overcome here, some of them possibly insurmountable. I hope your representatives will be prepared to meet with myself and colleagues to gain a deeper appreciation of the problems facing the development of new nuclear at the Bradwell site.
It would be appreciated if you would please e-mail your response to me as I am not always in residence at the address given above. My e-mail address is:
Andrew.blowers@open.ac.uk
I am sending a similar letter to the China National Nuclear Corporation.
Yours sincerely,
Prof. Andrew Blowers, OBE
Chair, Blackwater Against New Nuclear Group (BANNG)
Co-Chair, UK Government/NGO Nuclear Forum
Member of the first Committee on Radioactive Waste Management (CoRWM1)
Cc:
Rt.Hon. Bernard Jenkin, MP; Rt. Hon. Priti Patel, MP
15 June 2015
Vincent de Rivaz,
Chief Executive,
EDF Energy,
3rd. Floor,
Cardinal Place,
80, Victoria Street,
London SW1E 5JL
Dear Mr. de Rivaz
New Nuclear Power at Bradwell Site, Essex, England
I am writing to you as Chair of the Blackwater Against New Nuclear Group (BANNG) concerning proposals for new nuclear build at Bradwell. Since it was formed in 2008, BANNG has drawn attention to the reasons why Bradwell is a wholly unsuitable site for new nuclear build. We understand that EDF, as owner of the site, is in the process of seeking to sell it to Chinese developers who are interested in developing new nuclear reactors and radioactive waste management facilities in the UK. We are particularly concerned that the disadvantages of the site and the opposition to its development for nuclear purposes have been ignored or disregarded. I should welcome the opportunity to discuss with EDF and the Chinese companies with whom you are negotiating the problems surrounding development of this site.
There are five issues, in particular, that I think should be discussed. The first is the condition entered into under competition rules when the site was purchased by EDF. As I understand it EDF is not obliged to sell the site to another operator until planning approval to build two reactors at Sizewell has been achieved. At the time this was presumably seen as providing some protection from competition for EDF. It would appear that EDF is now prepared to sell the site to a potential competitor without such restrictive conditions. I should be grateful if you can confirm this to be the case and whether this has any implications for EDF’s investment in the UK nuclear industry.
The second issue is the problem of cooling water at the site. The Blackwater is a shallow estuary with a relatively slow recharge rate. The volume of cooling water required for two reactors of around 1.5GW each will far exceed the capacity of the estuary to supply it. Alternatives such as supplying from the sea or from cooling towers would raise difficult technical and environmental issues. Has this problem been considered by yourselves or the developers with whom you are negotiating?
Thirdly, there is the issue of the environmental and ecological damage that new nuclear power reactors might cause to the marine ecology and terrestrial environment. The Blackwater estuary is subject to many national, international and local environmental designations and has recently been accorded the status of a Marine Conservation Zone, affording special protection to the unique Colchester native oysters. Have the environmental considerations been fully considered in your negotiations?
Fourthly, the vulnerability of the coastline is, we believe, a significant issue and a major reason why new build at Bradwell should not be contemplated. The Essex coast is liable to the impacts of inundation, erosion, storm surges and coastal processes which are highly likely to increase as climate change reveals its destructive consequences in future years. New nuclear power stations could be operating until the end of the century and it is conceivable that radioactive wastes will remain in store on the site until the end of the next century. Have the possible consequences for managing the site over such a time period been fully considered?
Finally, BANNG is very concerned about plans to store spent fuel and other highly active wastes on such a site over such a time-scale and, perhaps, indefinitely. Plans for ultimate disposal of wastes are still at a very early stage and neither disposal concept nor a site has been determined. The prospect of Bradwell becoming virtually a permanent site for the storage of highly dangerous wastes in deteriorating conditions is extremely worrying. Again, it would be interesting to know the views of EDF and potential developers on this.
All these concerns have been repeatedly aired both in depth and in detail in the many well-researched papers BANNG has compiled in its various submissions to government, regulators and other bodies. All these papers may be found on our website (a list is attached for information). We have good reason to believe that the local communities around the Blackwater are overwhelmingly opposed to new nuclear at Bradwell. BANNG collected 10,000 signatures to a face-to-face petition opposing new reactors and spent fuel stores on the site, which was presented in person to the Minister for energy. This was surely the most comprehensive test of face-to-face public opinion undertaken at any proposed new nuclear site in the UK and we found around 80% of those approached were willing to sign.
The government’s National Policy Statement for Nuclear Energy (NPS) deemed Bradwell to be one of eight sites potentially suitable for new nuclear power. But, it also recognised that there were several adverse impacts that could rule out a site or the level of mitigation that would be needed to retain a site. In the NPS concerns were raised about development on dynamic shoreline exposed to coastal processes under the impact of climate change. These seem to us matters that might well rule out development at Bradwell and so should be considered at an early stage rather than waiting until resources have been deployed and development consent is applied for.
There are, then, some very serious issues facing any development of new nuclear energy at Bradwell which need to be taken fully into account during the course of the negotiations you are conducting with potential Chinese developers. I am requesting that we meet to discuss these matters of great importance to the substantial communities around the Blackwater estuary.
I look forward to hearing from you.
Yours sincerely,
Prof. Andrew Blowers, OBE
Chair of Blackwater Against New Nuclear Group (BANNG)
Co-Chair of UK Government/NGO Nuclear Forum
Member of the first Committee on Radioactive Waste Management (CoRWM1)
Cc Rt. Hon. Bernard Jenkin, MP; Rt. Hon. Priti Patel, MP