BANNG Column for Regional Life, November, 2018
BANNG’s visit to the Bradwell B site (reported on in the October edition) gave an opportunity to discuss the early site assessment undertaken by the company. The question in all our minds was: ‘is this a suitable site for the Bradwell B nuclear complex?’. At this stage the developer’s answer is nuanced: a case of we hope so but we are a long way from knowing.
The Bradwell project is currently under scrutiny by the regulatory authorities in a process known as Generic Design Assessment. Taken together the site assessment and the GDA provide an opportunity for BANNG to press concerns about three key issues which, we believe, make the site wholly unsuitable and unsustainable.
The first is the high probability risk of flooding ‘especially during the later stages of operation and decommissioning of a potential nuclear power station’. In short, is it conceivable that the site could be defended against the sea in the predicted conditions of rising sea levels, storm surges and coastal processes that are likely to overwhelm this coastline in the next hundred years or so? It is difficult to see how the redundant reactors and highly radioactive wastes including spent fuel in stores could be safely managed under extreme conditions.
Second, is the issue of providing the vast quantities of water needed to cool the reactors. If, as seems probable, cooling towers are ruled out on such a low-lying site, and the shallow waters and slow tidal refresh rate disqualify the estuary as a source of cooling water, then the only option would be direct cooling from the North Sea, requiring construction of high bore pipelines for around 5 km. across the Dengie Flats to reach deeper water.
The third issue is the environmental destruction this project would cause.
Looking out across the site, one is struck by the rural, tranquil and understated landscape and the sense of spiritual isolation conveyed by the 7th century St Peter’s Chapel, crude and solitary on the Saxon shore with nearby Othona, the remains of a Roman fort. The area is rich in ecology, with multiple designations, an estuary rich in salt marshes, reedbeds, ancient grazing marshes and deciduous woodlands, a haven for migrating birds, rare flora, fauna and invertebrates. All of this would be endangered and the area transformed into an industrial landscape.
These points, and more, we have put to the developers both in person and in writing. At this formative stage when the site is under investigation and the design is far from approval, the proposal is more generic than specific, so the response of the developers is vague and elusive. It’s all a bit like Brexit: progress is being made but there is much more work to be done.
‘We are passionate to ensure that any future power station is safe, secure and environmentally acceptable…You will appreciate that at this early stage we do not want to foreclose options, and we recognise there is more work to do to underpin the proposition for a new power station’.
On our three issues the developers’ response is predictably cautious. On flooding there is a tone of determination in the commitment to assessments which ‘will address the scenarios for extreme flooding, extreme tides, storm surge, tsunami, extreme rainfall, as well as the effects of climate change’, including ‘provision for events which we cannot today foresee’. If events cannot be foreseen it is surely impossible to provide for them! If we do not know what to do with the wastes and have no idea what conditions on the site will be like in 150 years time, then surely we cannot proceed, QED.
As to cooling water, the answer was gnomic. ‘The approach to cooling a power station will undoubtedly be significantly influenced by this environment’.
We did not elicit a response on our environmental concerns on the grounds that these relate to the specific site and are not part of the generic assessment. They will be taken into consideration during the planning and permitting stages of the process. But, BANNG believes some environmental issues are strategic and should preclude development at any site. In particular we would contend that, in cases like Bradwell, environment rather than development is an overriding public interest.
Sometimes the developers’ response borders on the fantastical. They say they will put in place ‘legally binding commitments to make financial provision for decommissioning and spent fuel storage’. Such commitments when the volumes and methods of management are unknown and the obligations extend into the far future must surely be meaningless. Words full of sound and fury, signifying nothing.
BANNG does not doubt the sincerity of the commitment to dialogue but we hope responses will be more forthcoming and the serious deficiencies in the Bradwell site will be recognised by the developers and regulators. In terms of engagement, a start has been made and, for BANNG’s part, we will endeavour to be critical and constructive while opposing new nuclear at Bradwell.