Concerns about the imminent discharge of radioactivity from Bradwell first raised by BANNG last summer have escalated in recent weeks in a concerted effort to put pressure on the authorities to halt the process. And there have also been calls to stop the proposed import of intermediate level wastes from Dungeness. As BANNG’s Chair Andy Blowers says, ‘There is a palpable and widespread sense of frustration at the lack of consultation, information and openness shown by the operators of Bradwell and the authorities that regulate their activities.
A veritable deluge of letters has been rained by BANNG on the operators (Nuclear Decommissioning Authority and Magnox), the regulators (Environment Agency, Marine Management Organisation), the local councils (Essex, Colchester, Maldon), Local Community Liaison Committee, MPs, MEPs, the Government (Department of Energy and Climate Change and the Secretaries of State for Environment and for Energy). Some well-informed BANNG supporters have also added their voices and efforts to the opposition. And now West Mersea Town Council and Oystermen’s organisations have also taken up the attack. So far, response has been slow and when it comes is rather defensive and complacent, falling back on technicalities of regulation and practice to soothe fears and provide reassurance. As Barry Turner, Vice-Chair of BANNG comments, ‘We wait ages for a reply and, when it eventually comes, it raises more questions than it answers.’
FED stretches the limits
Among the questions raised about the Fuel Element Debris (FED) dissolution process is how it was permitted and whether it should have been permitted at all. The Environment Agency has revealed that in order ‘to allow for the treatment of FED, the gaseous radioactive discharge limits in the Bradwell site permit…were changed in September 2012’. In short, they were increased.
However, the EA can fall back on the requirement to apply Best Available Technology (BAT) to ensure the impact on the public and environment is As Low As Reasonably Achievable (ALARA). In terms of BAT, the nitric acid dissolution process being used is, in fact, new and untried at a commercial level. Barry Turner comments, ‘Why has the Environment Agency permitted deliberate releases of radioactivity by the NDA by approving the piloting of a new and untested nitric acid dissolution process in a restricted low refresh rate estuary which hosts many water based activities in close proximity to the discharges?’
As for the limits being ALARA the question arises as to whether the discharges contravene the OSPAR (dumping waste at sea) Convention. To which the NDA blithely replies that the discharges will have ceased by 2020 ‘and therefore should not interfere with the OSPAR Treaty which seeks to reduce discharges close to zero by 2020.’ Varrie Blowers, BANNG’s Secretary, was incensed by this reply, ‘It is outrageous to allow discharges to occur which we know will be outlawed in a few years time. It is not as if it is necessary since FED can be managed without dissolution, as is the case at other nuclear sites’.
There is also the question, raised by West Mersea Town Council of whether the dissolution plant requires planning permission since, under current permissions, waste must remain in situ within the site boundaries and not create additional pollution. Dissolution results in the discharge of 15% of radioactivity into the air and sea around the plant.
Keep ILW within bounds
When it comes to the proposed transfer of ILW from Dungeness to Bradwell the question of planning permission also arises. BANNG, along with Maldon Borough Council and West Mersea Town Council are opposing the transfer on the grounds that it imposes extra risks resulting from handling, transportation and storage as well as increasing the radioactivity on the Bradwell site.
The NDA are proposing to use some spare capacity in the new ILW store purposely built to house ILW from Bradwell. But, it appears they will need a new planning permission for what would, in effect, become a regional nuclear waste store. Essex County Council are being urged to deny permission. There is also the question of compensating local communities for bearing an extra burden of risk extending into the future.
Andy Blowers comments, ‘If waste is imported into Bradwell it could set a precedent for creating a regional ILW store. This might be the first step on the road to a fully fledged waste store, especially if new build ever comes to Bradwell. And, with the Government about to renew their search for a deep disposal facility, places like Bradwell come under the spotlight. Bradwell is just simply not an acceptable site for accommodating the massive volumes and radioactivity that would be involved.
‘However, another precedent has now been set. The united opposition to FED discharges and the import of ILW is as nothing compared to what would happen if new nuclear power stations and high level radioactive waste dumps were proposed to contaminate and despoil the Blackwater estuary. Developers from whatever country and our Government have been warned.’