On 25 August, a team from BANNG met with key officers from the Environment Agency, David Griffiths, Team Leader (South) and Karl Littlewood, Nuclear Regulator (South). The main item for discussion was the application by Magnox to extend its permit for discharges arising from the dissolution of radioactive fuel element debris (FED) from Bradwell for a further 24 months.
BANNG argued that as the original permit for discharges to be carried out for 12 months had already expired, a new permit should be applied for and not a variation to the original. The EA said that the original permit had not expired only the time-limit of 12 months. Discharges arising from FED dissolution would, therefore, continue until 2017, with the site entering Care and Maintenance in 2018, instead of at the end of 2015 as had long been promised.
After the meeting BANNG’s Chair Andy Blowers said: ‘It is clear that the EA have every intention of granting this extension despite objections. We are naturally disappointed but I cannot say we are surprised’.
BANNG argued that the discharges should stop on the grounds that:
- the dissolution process is clearly not working and the technology is unreliable; the
plant has not performed well and has shut down for long periods to deal with technical challenges;
- it was unclear how many and when discharges had taken place, resulting in great uncertainty;
- the dissolution process cannot be said to fall under ‘Best Available Technology’ (BAT) as it will not be used at other sites as originally planned; the BAT for these is storage on site;
- the need for the process was based on considration of costs rather than on minimising risks to health and environment;
- although the permit was for Bradwell FED only, there must always remain the possibility of FED coming from other sites for dissolution at Bradwell;
- it had been demonstrated that there was a great deal of public anxiety about the discharges;
- misinformation and the unreliability of the process had led to a lack of trust in the capability and competence of the operator.
Barry Turner, Vice-Chair of BANNG, commented: ‘Although the EA confirmed that the permit remains for dissolution of Bradwell waste only, our objections that the process was unnecessary and unreliable were dismissed as irrelevant or unconvincing. The EA relied on the argument that the permit had already been granted, there were no new circumstances and the operator could continue to discharge until all the FED from Bradwell had been eliminated’.
Ian Clarke, one of the BANNG team, pointed out that other possible options did not seem to have been considered such as:
- the use of settlement tanks to further reduce the chemical and radioactive content of the effluent;
- putting the effluent in tankers for discharge into the open sea instead of into the Blackwater Marine Conservation Zone (MCZ) – the estuary has a low refresh rate and is in effect not more than a three-sided lake.
The EA indicated that these points would be worth making in response to the consultation.
‘All in all’, as Andy Blowers said, ‘if dissolution had been proposed now by the operator (which it wouldn’t be), it would not be approved by the Agency’.
Misinformation and Public Consultation:
BANNG pointed out to the EA that it believed that the public had been consistently misled over the years about the nature of the FED discharges. At various Bradwell Local Communities Liaison Council (LCLC) meetings – whose members report to the public – the discharges had variously been referred to as ‘benign liquid’, ‘benign effluent’, ‘essentially clean water containing Magnesium salts’, ‘an aqueous discharge of a clean salt solution’. It was also said that the abatement plant would ‘remove waste and activity’.
Varrie Blowers, BANNG’s Secretary said: ‘Far from being a harmless liquid solution it had become clear that the discharges contain radionuclides, heavy metals and nitrates.’
Another member of the BANNG team, Graham Farley, was concerned that no reason had been given for the need to extend the discharges and at the paucity of mention in the consultation papers of the recent designation of MCZ for the estuary. He said: ‘No-one seems to know the volumes, timing and number of discharges that have taken place although the EA did comment that these are not taking place every day as originally planned but several times a month’.
It was noted that Priti Patel, MP, had been told by a member of the EA that ‘the general public’ had been invited to comment on the current consultation. However, the extent of public consultation had been nugatory, restricted to less than a month during August, the height of the holiday season. The EA had ‘taken the decision not to publish the proposal in the local press but to publicise it on our website and then to notify people we know have an interest in the matter directly. We considered this form of targeted approach to be the most effective in this case’.
At the end of the meeting, Prof. Barry Jones from Tollesbury commented: ‘It has become clear during discussions that, although a consultation is currently taking place, granting of the variation is more or less a foregone conclusion. And it seems entirely possible that if the dissolution process continues to fail that, unfortunately, discharges could continue for an even longer period.