OPTIMISING THE NUMBER AND LOCATION OF FED TREATMENT (DISSOLUTION) FACILITIES IN MAGNOX LIMITED – CREDIBLE OPTIONS. NUCLEAR DECOMMISSIONING AUTHORITY, MAY, 2013
RESPONSE OF THE BLACKWATER AGAINST NEW NUCLEAR GROUP (BANNG)
BANNG Paper No. 21
This strategy paper assumes a public acceptance of the fuel element dissolution (FED) process as a safe method of reducing the costs of radioactive waste disposal during decommissioning of Magnox nuclear power stations.
BANNG fundamentally disagrees with this assumption because the FED dissolution process also causes unnecessary releases of radioactivity harmful to human health and the environment. These radioactive releases and consequent risks can be avoided by packaging and storing untreated FED.
Fuel Element Debris Disposal
Fuel Element Debris is produced when the metal casings and fins are removed from Magnox fuel rods before the spent fuel is sent to Sellafield for reprocessing and storage. This intermediate level radioactive FED waste collects in vats and tanks over the lifetime of Magnox nuclear power stations and is only cleared during decommissioning.
Three methods of handling FED waste at decommissioning Magnox sites feature in NDA documentation.
1. Packaging and long term storage, as at Berkeley, Hunterston A and Trawsfynydd.
This method results in the minimum of radioactive releases into the environment.
2. The carbonic acid dissolution process, as at Dungeness A.
In their Credible Options main paper the NDA describe the effects of the acid dissolution process:
‘Through treatment with acid, FED dissolution produces a non-reactive waste,
reducing the solid waste volume by more than a factor of 20 whilst retaining more than 85% of the radioactivity in residues that will be managed along with other ILW wastes at the site.’
3. The nitric acid dissolution process, as at the remaining Magnox sites.
This process also reduces volumes by a factor of 20 and retains more than 85% radioactivity but operates far more rapidly than the carbonic acid process.
No detail is provided regarding the nature of the ‘missing’ 15% of radioactivity which would no longer be present in the reduced volume of waste, which is packaged after being processed.
Dissolution will, therefore, result in a discharge of this 15% radioactivity into the atmosphere, into the sea, or both.
BANNG opposes use of the dissolution process for FED disposal due to the unnecessary and deliberate radioactive discharges harmful to the environment and human health which it produces. All FED should be safely packaged for long-term storage as at Berkeley, Hunterston A and Trawsfynydd.
Optimising FED Treatment (Dissolution) Facilities
The stated purpose of the NDA in optimising the number and location of FED treatment facilities in Magnox sites is to,
‘….consider the possibilities to reduce overall costs, reduce overall environmental impacts, and reduce overall timescales of decommissioning by consolidating ILW management at fewer locations.’
That is, to reduce costs by transporting the waste from the source site to another where it undergoes dissolution and storage, rather than processing and safely storing waste on the site where it was produced. (Please also see BANNG Paper No. 20 responding to the strategy paper on ILW storage optimisation.)
This strategy paper on (FED) offers a range of choices restricted to the NDA’s prepared list of credible options which:
‘aim to establish the most appropriate location or locations for treating FED currently stored at Hinkley Point A, Oldbury and Sizewell A sites.’
BANNG asserts there should also be a NO FED DISSOLUTION option as the means to reduce radioactive discharges to a minimum. We also assert that the NDA should comply with their own objective to reduce environmental impacts. FED should be packaged for long- term, safe storage on the sites where it is produced as the optimum environmental solution. Cost-saving schemes which compromise human health and the environment should have no place when dealing with these hazardous wastes.
The FED Dissolution Process Contravenes International Agreements
The FED dissolution process, which would lead to an increase of environmental discharges of radioactivity, is not in accordance with the agreed objectives in the following extract from the NDA strategy paper relating to the OSPAR international treaty.
‘By the year 2020, the OSPAR Commission will ensure that discharges, emissions and losses of radioactive substances are reduced to levels where the additional concentrations in the marine environment above historic levels, resulting from such discharges, emissions and losses, are close to zero’.
The NDA strategy paper clearly states its agreement with this objective, which requires a policy to concentrate and contain radioactive waste safely, not to discharge and disperse it.
BANNG requests the NDA to reject the dissolution process and comply with the UK Government’s commitment to international agreements for near zero radioactive discharges.
Inadequacy of Public Consultation
The NDA held a Bradwell decommissioning update meeting at West Mersea on 29 May, 2013 which included reference to the strategy papers on ILW storage and FED dissolution, along with a routine decommissioning update. The people of Mersea Island very much appreciate having these opportunities to hear what is happening on their doorstep and to participate in open discussions.
Sadly, the advertising for this event ignored the existence of the strategy papers and, worse still, only appeared in one newspaper which has low readership in the area. As a result only 12 members of the public attended, and of these 7 only heard through a personal contact who had attended the LCLC meeting 2 weeks previously, where the meeting was also announced. The closing date for submitting evidence was originally 9 June, only 12 days after the meeting. In response to criticisms this was later extended to 30 June.
NDA staff repeatedly described these as ‘consultations’ at the LCLC and West Mersea meetings. These ‘consultations’ were nowhere to be found on the NDA website under the Consultation heading. We were also advised the information could easily be found prominently shown on the website main home page when this was not the case. A few days after the meeting the front page was changed to correct the situation but it was still not a consultation as described by NDA staff, only an invitation to stakeholders to submit comments.
BANNG deplores the lack of an open, honest and transparent public engagement process, and in particular, the lack of a full consultation on FED dissolution.
Complete Unsuitability of the Bradwell Site for FED Dissolution
One of the main reasons why the Bradwell site does not appear in the NDA list of appropriate locations for treating FED from other sites is the following statement from the Environment Agency quoted in the strategy paper:
‘ the Bradwell site is sub-optimal in terms of longer term environmental impacts, as would occur if Bradwell was used as a shared plant.’
This indicates the Environment Agency considers Bradwell is not an ideal site for FED dissolution and BANNG maintains this further supports our view that the process should not be implemented there.
In addition to the reasons already listed for opposing any use of FED dissolution, there are more specific conditions in the Blackwater Estuary which would make its use at Bradwell particularly damaging.
The Blackwater is a shallow tidal estuary. It takes 10 days for successive tides to refresh the water totally. The estuary includes many well-documented and extensive environmentally protected areas, protected marine species and it also supports fishing and water-borne leisure industries, holiday beaches and a unique oyster industry which cultivates the world famous Colchester Native Oysters.
All of this takes place within 2 miles of the proposed area for deliberate releases of radioactivity.
BANNG maintains FED dissolution must not be allowed at Bradwell.
Barry Turner, Vice-Chair,
On behalf of the Blackwater Against New Nuclear Group (BANNG)
30 June, 2013