Env. Agency announces permit approval for Bradwell (Essex) FED discharges
The Environment Agency for England and Wales announced, 14th March 2017, a decision to grant a new series of Permits to Magnox Limited’s Bradwell nuclear power station (decommissioned) to discharge nitrates, heavy metals and radionuclides into the Blackwater Estuary MCZMCZ Marine Conservation Zone/SPASPA Special Protection Areas (SPAs) are strictly protected sites classified in accordance with Article 4 of the EC Birds Directive, which came into force in April 1979. They are classified for rare and vulnerable birds (as listed on Annex I of the Directive), and for regularly occurring migratory species./SACSAC Special Areas of Conservation/SSSISSSI Site of special scientific interest arising from the process that will treat fuel element debris (FED) currently stored on site.
This treatment involves dissolving the FED material in nitric acid, recovering the radionuclides, and discharging the remaining nitrates, heavy metals and radionuclides on the ebb tide into the estuary. This discharge would likely occur daily, and take place over two years — although the permit is not time limited to allow for any alteration in the frequency of discharges (i.e. less than one per day) but the permit is limited to the known volume of FED material.
The Environment Agency’s statement, 14th March 2017, of approval reads:
Environment Agency environmental permitting decision
Permit reference: EPR/DP3127XB/V002, PR2TSE10760/V003 and EPR/ZP3493SQ/V005
Operator: Magnox Limited
Facility: Bradwell Site
Dear Sir/Madam
As you are aware, we have been considering Magnox’s request for changes to the Environmental permits for the Bradwell site. The changes requested include:
- An extension to continue discharging liquid effluent, from the fuel element debris treatment process (FED), into the estuary
- An option to switch the existing discharges to a new outfall structure in case the existing outfall becomes blocked by a build-up of silt
- A Radioactive Substances application to allow the switch to the new outfall structure when necessary
We have completed our thorough review of all of the representations submitted during the second public consultation for these permit variations which ran from 20 October — 15 December 2016. We are now ready to issue all 3 permit variations. Please find attached further information about our decision and some frequently asked questions.
How to view the decisions documents and updated permits
The decision documents explain how we have addressed all of the comments we received during the consultation. These documents, along with the final permits are available to view online at: www.gov.uk/government/publications/cm0-7hp-magnox-limited-environmental-permits-issued.
This information is also held in a register at the following location: The Environment Agency, Public Register, Iceni House, Cobham Road, Ipswich, IP3 9JD. You can look at our register 9.30am-4.30pm, Monday to Friday. To arrange an appointment, or if you have any questions about these permits, please contact our National Customer Contact Centre on 03708 506 506 or email email hidden; JavaScript is required.
Regards
Permitting Support Advisor
Permitting and Support Centre
National Permitting Service (Part of National Services E & B)
Permitting Support Centre, Quadrant 2, 99 Parkway Avenue, Sheffield, S9 4WF
Marinet Observes: Marinet has consistently opposed a decision to dissolve the fuel element debris (left-over miscellaneous metal material associated with the fuel rods) because it believes that the process is both unnecessary and will, when undertaken, cause additional pollution that is wide-ranging in nature (nitrates, heavy metals and radionuclides) in an estuary that is a Marine Conservation Zone on account of its native oysters (Ostrea edulis) which are still harvested commercially, and is a SAC/SPA and SSSI because of its wild bird populations and related habitats.
When Magnox Limited, which owns Bradwell, originally applied to the EA in 2014 for a FED Permit, which was granted, the permit was surrounded by a great deal of controversy because it was alleged that no Appropriate Assessment had been undertaken under the Habitats Regulations to evaluate the impact the discharges on the estuary’s SAC/SPA and SSSI, and certainly not on the estuary’s MCZ. Thus the new Permit submission, and subsequent consultation, has been to determine whether everything is legally and environmentally sound.
Marinet believes that the FED dissolution in nitric acid is unnecessary for two reasons.
Firstly, as was originally proposed, the fuel element debris could have been encased in concrete and stored in solid form. This would have resulted in no release of radioactivity, heavy metals or nitrates.
However, Magnox decided to dissolve the material in acid in order to “extract” the radionuclides and thus reduce their “volume” for storage purposes and secured a Best Practical Environmental Option certificate (BPEO) for this purpose, only it originally proposed to use carbonic acid and not nitric acid. Nitric acid however speeds up the dissolution process, but creates an additional nitrate waste disposal problem — in this case, discharged into the estuary.
Thus secondly, the nitrate burden on the environmental condition of the estuary — currently of only “moderate” under the Water Framework Directive due to nitrate pollution and so in need of improvement — could have been avoided if the original use of carbonic acid had been adhered to.
Notwithstanding these objections, which Marinet observes appear to have counted for little in the EA’s evaluation of the new Permit application, Marinet has held that:
- The studies by the applicant’s consultant, HR Wallingford, demonstrate that additional nitrate discharges into the estuary due to the FED process will cause significant accumulation of dissolved nitrates in the estuary’s waterbody, and thus significant adverse impact under the Water Framework Directive, Habitats Regulations and the Marine and Coastal Access Act.
- The studies by the applicant showed that heavy metal levels, particularly Chromium, will be released in substantial amounts, and Marinet believes that these will add to the burden of these metals in estuary sediments and marine life in a context where the existing levels of a number of these metals are already exceeding precautionary environmental limits.
- The studies by the applicant of radionuclides to be discharged into the estuary were poorly characterized as to the nature and the quantities of the radionuclides to be released (i.e. the radioactive material not recovered during the FED process), and consequently there exists, if the Permit were to be granted, an unquantified additional risk to human and biological life in the estuary.
The Environment Agency dismissed all of Marinet’s concerns (ref. Decision document EPR DP3127XB, pages 80 onwards).
What can Marinet, and indeed others who have opposed this Permit and the licensing procedure, say? We could accept gracefully that our opinions were wrong, but we do not believe they were. Instead we have to, respectfully, bow before the decisions of our administrative powers.
These decisions could be challenged in a Court of Law by means of Judicial Review, but who amongst us has the depth of pocket to finance such a course, especially now that legal aid has effectively been abolished for these purposes (protection of the public interest)?
Perhaps the solution is that this whole permitting process, its evidence and evaluation, should have been subject to independent scrutiny via a Public Enquiry performed by the Planning Inspectorate.
But that is probably pure wishful thinking. Meantime, the people and wider world which lives in the estuary will have to live with the consequences. Marinet very much regrets this.
