COMMENT PAPER ON THE PREFERRED OPTION OF THE NUCLEAR DECOMMISSIONING AUTHORITY (NDA) FOR OPTIMISING THE NUMBER AND LOCATION OF:
INTERIM INTERMEDIATE LEVEL WASTE (ILW) STORAGE FACILITIES ON MAGNOX LIMITED AND EDF ENERGY SITES;
FED TREATMENT (DISSOLUTION) FACILITIES IN MAGNOX LIMITED
COMMENTS FROM THE BLACKWATER AGAINST NEW NUCLEAR GROUP (BANNG)
(BANNG PAPER NO. 24)
1 Preferred Option for Fuel Element Debris (FED) Treatment (Dissolution)
Facilities in Magnox Limited
Bradwell FED Dissolution Plant
The FED treatment strategy excludes Bradwell from consideration in this consultation on the grounds that it is not considered a recipient site and has a dissolution plant commissioned for its single use. The Blackwater Against New Nuclear Group (BANNG) objects to dissolution at Bradwell and intends to include objections to it in this response since (a) it is a trial experiment and (b) has not yet started its operations. We believe that the aqueous discharges of radioactivity, nitrates and heavy metals arising from FED dissolution will jeopardise the delicate and significant environment and ecology of the Blackwater estuary. The importance of these has been acknowledged by the recent designation of the estuary as a Marine Conservation Zone (12 December, 2013).
BANNG, therefore, urges the NDA not to proceed with dissolution at the Bradwell site.
The Preferred Option paper, in common with previous calls for evidence, 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.
This decision by the Nuclear Decommissioning Authority (NDA) has been made without giving the public an opportunity for a full consultation. No reasons have been given for this omission.
Page 5 of the ‘Preferred Option’ paper states:
‘The review does not consider FED treatment technology or whether dissolution is the appropriate management solution for FED, both of which have been subject to separate Best Practicable Environmental Option (BPEO) assessments at the relevant Magnox sites. The choice of acids is not considered to affect the conclusions of the review but, for the purposes of the project, Magnox has made an assumption that any new FED treatment plant would be nitric acid based. Magnox has made a commitment to review experience of operating the Bradwell dissolution facility, which will use nitric acid, before making a decision on the appropriate acid choice for any new FED treatment plant.’.
BANNG has previously stated its concerns regarding the FED dissolution process and in particular its use at Bradwell and, unfortunately, these concerns remain since no satisfactory responses have been received from the NDA to allay them.
Radioactive Discharges into the Environment
In the ‘Credible Options Main Paper’ of May 2013, section 1.2, the NDA described 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 intermediate level wastes at the site.’
This information does not appear in other NDA documentation, but here it clearly states a figure of 85% (or more) of the radioactivity is retained, with the result that 15% (or less) is ‘lost’ through discharges either to the atmosphere or through discharges into the sea, or both.
It is reasonable to suppose that if the radioactivity retained in the residues was higher than 85% then the figure quoted in the NDA statement would be that higher figure, so by inference 15% of the radioactivity might be discharged.
The fact that dissolution only retains 85% of radioactivity and can then discharge 15% into the environment has never been specifically stated by the NDA at local public meetings or Bradwell Local Community Liaison Committee (LCLC) presentations. The result of this failure is that most members of the community, who will not have waded through the many pages of reports, will naturally believe the dissolution process to be perfectly harmless. The NDA has routinely referred to the discharges as ‘aqueous discharges’, reinforcing this impression.
A question was raised about the 15% radioactive discharges at a Bradwell LCLC site visit meeting on 14 October, 2013 but the Site Director was not aware of this figure and could give no clarification, stating that any discharges would be within permitted limits. The question of the 15% discharges of radioactivity was again raised at another Bradwell LCLC meeting on 11 December, 2013 and again the response given to the meeting was that they were minor compared to the past. No clear answer was given to the question asked about what the discharges would contain.
This does not seem to agree with the NDA Credible Options document since it is hardly believable that up to 15% of the radioactivity in ILW could be considered a harmless discharge into the environment.
It is also clear that the Environment Agency considers that the proposed aqueous discharges containing radionuclides, nitrates and heavy metals into the Blackwater estuary are at the margins of what the estuary can safely tolerate: ‘whilst the short-term impacts of discharges have been deemed to be acceptable (and the relevant permit obtained), the Bradwell site is sub-optimal in terms of longer term environmental impacts, as would occur if Bradwell was used as a shared plant’ (2013, p. 10).
BANNG, therefore questions the use of the dissolution process for FED disposal due to the resulting unnecessary discharges of radionuclides, heavy metals and nitrates to the environment. FED at all sites should be safely packaged for long-term storage as at Berkeley, Hunterston A and Trawsfynydd.
The FED dissolution process contravenes International Agreements
The FED dissolution policy, 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 Document 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 Document clearly states its agreement with this objective which requires a policy to safely concentrate and contain radioactive waste, not to discharge and disperse it.
The NDA should reject the dissolution process and comply with the UK Government commitment and their own commitment to the OSPAR international agreement for near zero radioactive discharges by packaging FED as at Berkeley, Hunterston A and Trawsfynydd.
Faster Process, More Pollution, Higher Risk?
The Preferred Option is intended to reduce costs and reduce environmental impacts. The dissolution process at Dungeness using carbonic acid is a slow one processing 10 tonnes per annum. The new process to be launched for trial at Bradwell uses nitric acid and will process 100 tonnes per annum – ten times faster than that at the Dungeness plant. This will, therefore, lead to ten times the rate of radionuclide and heavy metal releases into the Blackwater. There will also be undesirable nitrate discharges into the estuary as a result of nitric acid dissolution.
FED Dissolution at Bradwell
Coastal conditions at Bradwell, which is situated on a shallow, narrow estuary, are significantly different from those at Dungeness, which is situated on a headland in 25 miles of open sea, and make it unsuitable for FED discharges, particularly at ten times higher rates. It is, therefore, an unwise decision for the NDA to have selected the Bradwell location for trials of the new process. In particular, the following factors indicate why FED discharges into the Blackwater estuary should be avoided.
• The tidal refresh rate for the Blackwater Estuary is ten days which means pollution will take far longer to disperse.
• The ten times faster throughput rate for nitric acid treatment means ten times higher rates of radioactive discharge.
• The Blackwater has many nationally and internationally protected environmental areas and protected species.
• There may be risk probabilities for harm from the discharges to the marine life, including the Colchester Native Oyster, in the Blackwater estuary and the ways in which they vary according to the volume and rates of the discharges and to tidal flow variations.
• The Blackwater supports a wide range of employment in the marine sector, including fishing and cultivation of the renowned Colchester Native Oyster, now protected by the recent Marine Conservation Zone designation of the Blackwater Estuary. All are within close proximity to the proposed radioactive discharge outlets.
• The whole estuary attracts a high density of waterborne leisure activities such as yacht sailing, dinghy sailing, canoeing, windsurfing and kitesurfing, many often taking place within metres of the proposed radioactive discharge outlets. There may be risk probabilities for harm to them from the discharges and these risks will vary according to the volume and rates of the discharges and to tidal flow variations. Should people be warned not to use the estuary when discharges are planned to take place?
• Within only two miles of the discharge point is the town of West Mersea with its popular and often crowded leisure beaches and hundreds of beach huts. There are many other residential, holiday and leisure areas within a few miles of the radioactive discharge outlets.
• The dissolution plant still awaits the installation of new pipework for intake and pump out of discharges. These pipes are to be installed within the disused cooling ducts of the former nuclear power station. Over the years these ducts have become packed with hundreds of tonnes of silt and this must first be removed before the new pipes can be installed. Oystermen say this work is considerably behind schedule with only some 68 tonnes removed so far. The work must, however, be completed soon or the wide dispersion of the removed silt would cause severe damage to the native oyster breeding season, so silt removal would have to be postponed until next year, preventing the planned entry of the site into care and maintenance around the end of 2015.
• It is unclear if the silt that is being removed still contains any of the biocide that was previously used to clean the pipes or if it contains radioactivity. This silt will be deposited in the estuary.
• A natural consequence of tidal movements across the mudflats in the shallow Blackwater estuary is to increase its salinity, said to be the highest in the country. This has led to the production of sea salt here since Roman times. This is also testament to the likelihood that radioactive and chemical pollution which is repeatedly introduced into the Blackwater may become more concentrated rather than diluted.
• The importance of the Blackwater estuary was demonstrated by its designation, along with the Crouch and Roach rivers and Colne estuary, as a Marine Conservation Zone which came into force on 12 December, 2013. In particular, this provides specific protection to the Colchester Native Oyster and its habitat. The deliberate discharge of pollution and silt into the river Blackwater oyster beds is clearly incompatible with this designation.
• Unusually heavy rainfall, strong onshore winds, storm surges and coastal flooding/inundation – during this winter (2013/14) – may be responsible for dispersing radioactivity. BANNG has been made aware of a report by an independent Marine Radioactivity Consultant that claims that the recent extreme winter weather conditions on UK coasts are likely to have generated an increase of radioactivity doses to some coastal populations through increased sea to land transfer of sea-discharged radioactivity. The report concludes that these have occurred on all UK coastlines during the winter of 2013/14. We understand that the Environment and Public Health Agencies are being made aware of these issues.
We have not been able to obtain evidence that all these factors have been taken into account in the decision-making processes of the NDA. BANNG has, therefore, submitted written enquiries regarding the levels of radioactivity which will be released and the local factors which may cause normal assumptions of radiation risk to be revised in the case of Bradwell. Enquiries were submitted on 16 October, 2013, 6 November, 2013 and again on 15 January, 2014.
After receiving a vague reply to the first enquiry regarding the make up of the NDA documented 15% discharges of radioactivity (which NDA presentations have not even acknowledged), the following list of questions was emailed to the NDA on 6 November, 2013:
‘Thank you for your response to my enquiry (16th October).
Unfortunately the reply does not actually state what percentage of the original FED radioactivity is discharged into the environment. Can you please provide the following information?
1. The total amount of radioactivity which is predicted to be discharged into the environment during the Bradwell FED dissolution programme, broken down to show air discharges and discharges into the Blackwater, by radionuclide. Over what period discharges will be made?
2. What is the potential for harm to the local population from the discharges, either directly or through consumption of local oysters, fish or locally grown produce. Over what period will these risks continue?
3. The river Blackwater has the extremely low rate of ten days for tidal replenishment so even if pump out takes place at high water much of this contaminated water will return on the following tide. Has this been taken into account when assessing health risk?
4. It is well known that evaporation from exposed mud banks coupled with 3. above, leads to increased levels of salinity (and salt production) in the estuary. This effect of the Blackwater could retain and concentrate any radioactive discharges. Has this also been taken into account when assessing health risk?
5. Many young children and adults enjoy sailing and windsurfing throughout the year on the Blackwater, often coming within a few METRES meters of the discharge area. There is also a great deal of swimming from local beaches within 2 miles. Whatever the answers to all of the previous points, can it still be absolutely stated that there are no health risks or accumulated health risks to any members of the population or their children from repeated exposure to discharges or contaminated water/air/environment in this way?’
The NDA replied on 24 January, 2014 that they have had resourcing issues in the Information Governance Department and that they will respond as soon as possible. We consider a reply should be given before they proceed further with dissolution and discharge into the estuary.
In the meantime there remains considerable concern that the Blackwater estuary with its many environmentally protected areas and protected species should be selected for piloting a new, untried and more rapid scheme of FED dissolution that will result in unnecessary risk from uncertain levels of polluting radioactive and chemical discharges.
BANNG has also recently been made aware that it is proposed that of the Tritium in the FED to be discharged to the environment, 65% will go into the Blackwater estuary and 35% into the air. We do not believe that this discharge of Tritium to the air has ever been spelled out at any meetings by the NDA, including those of the LCLC. BANNG is extremely concerned about what it believes are proposed discharges of Tritium to the air. Mersea Island lies under the prevailing wind from Bradwell and discharges of Tritium to the air would pose risks for the substantial population there. Such discharges were already stopped on a previous occasion as a result of local opposition to the previously proposed trace radioactive waste burner.
BANNG asserts there should be a NO FED DISSOLUTION OPTION for ALL sites as the only means to reduce radioactive discharges to a minimum and to accord with the NDA’s alleged adherence to the OSPAR Convention. We also assert that the NDA should comply with their own objective to reduce environmental impacts by avoiding unnecessary transport of FED or ILW to other locations. 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.
In the event that the NDA persists with implementing dissolution at Bradwell, despite the risks to human health and the environment, BANNG demands that it should be required to run a full public consultation. The public should be made aware of what the proposed discharges would contain. The public should also be made aware of the constituents of the silt that is being removed from the disused cooling ducts at the former Bradwell power station and that will be deposited in the estuary.
If dissolution at Bradwell does go ahead, BANNG also demands an agreement to provide a completely independent and rigorous monitoring of the releases and accumulations of radioactive and chemical pollution to water and air around the Blackwater Estuary in order that there is proof there is no hazard to health or environment from the processing of FED. If any potential harm is detected, then operations must cease forthwith.
BANNG would like information on the future plans for the Bradwell single use dissolution plant, whether or not dissolution takes place at the site.
2 Preferred Option for Intermediate Level Waste (ILW) Storage Facilities on
Magnox Limited and EDF Energy Sites
BANNG is opposed to the Preferred Option and believes that each site should host its own waste as originally planned. The group reiterates its belief that ILW should not be transported from one site to another. The group fears that the current proposals could be the thin edge of the wedge and may lead to potential pre-emption of the relevant sites as regional stores. It believes the NDA is making strategy in a piecemeal way: there are, after all, no plans for how to deal with, for example, wastes from Wylfa which the NDA regards as a problem for the future. There should be no question of enlarging the ILW store at Bradwell or of using its spare capacity for the importation of ILW from Dungeness.
BANNG wishes to make it clear that it does not consider that storage of nuclear wastes on sites for at least a century – or indefinitely if no Geological Disposal Facility (GDF) is forthcoming – can be described as ‘interim’. Such storage is ‘long-term’ and the use of ‘interim’ is a misnomer.
Changing Conditions at ILW Storage Sites
BANNG believes that over the long-term, with the prospect of climate change, the conditions at the sites hosting ILW will become a significant consideration (e.g. vulnerability to flooding with sea-level rise, storm surges, etc.). Sea levels are predicted to rise by the end of the century when ILW will still be stored at sites. This may lead to sites needing to be abandoned.
Bradwell is just such a vulnerable site, sitting as it does on the shallow and narrow Blackwater estuary. The recent storm surge (December, 2013) coupled with a very high tide led to flooding around the estuary and should give the NDA pause for thought.
BANNG considers that the NDA must take into account the predicted changes to sea- level rises in a proper and well thought-through strategy for the storage of the nation’s radioactive wastes.
BANNG believes that the Bradwell site is totally unsuitable for storage of additional wastes as it sits on a shallow, narrow estuary with an important marine environment, acknowledged by the designation of Marine Conservation Zone. It will be vulnerable to flooding and storm surges by the end of the century due to climate change and sea-level rise, when ILW will more than likely still be stored there.
Terrorism and Site Security
BANNG notes that there is still no mention in the Preferred Option paper of any risk assessment having been made of the possibility of terrorism in relation to ILW stores. BANNG believes that the threat of terrorism – or even of interference – cannot be ruled out.
In relation to Bradwell, under its Care and Maintenance (C & M) status, it is proposed that the site will be managed from a remote hub with occasional on-site monitoring. If packages of ILW were to be transferred from Dungeness A, this would necessitate the opening of the site and the ILW store to receive them. This would compromise the C & M status.
Communities local to Bradwell may not feel that the way in which the site will be managed remotely when in C & M and the opening of the ILW store to receive ILW from Dungeness A, constitutes safe and secure storage.
Recommendation 2 of the first Committee on Radioactive Waste Management (CoRWM1) Proposals for Implementation (2007, p. 13) states that ‘reviewing and ensuring security, particularly against terrorist attacks’ is an important part of storage.
BANNG agrees with CoRWM1 that it is important to review and ensure security at ILW storage sites, particularly against terrorist attacks. The group is concerned that management of the Bradwell site, hosting very large volumes of ILW in reactor cores and stores, from a remote hub may be too light touch.
BANNG believes that ILW should remain on the sites of origin. Transfer of ILW flouts the principle of self-sufficiency, with each site managing its own wastes. The risks of disruption from transfer and safety risks arising from storage of larger volumes of wastes outweigh the savings that might be achieved.
Local Communities: consultation and compensation
Local nuclear communities should not be taken for granted – which is what is happening at present – and be expected just to host storage of ILW in the long-term, or indefinitely – and especially not wastes from other sites. BANNG is strongly of the view that communities hosting ILW in the long term should be properly consulted and afforded compensation to enhance their well-being.
BANNG believes the long-term storage of wastes is an issue of public interest, especially for those communities who have to host them, which, as we say above, should not be taken for granted. A proper siting process for storage is necessary – as recommended by CoRWM1 (2007, Recommendation 2):
‘A robust programme of interim storage must play an integral part in the long-term management strategy. The uncertainties surrounding the implementation of geological disposal, including social and ethical concerns, lead CoRWM to recommend a continued commitment to the safe and secure management of wastes that is robust against the risk of delay or failure in the repository programme.’. (p. 13)
BANNG will be urging Essex County Council to refuse Planning Permission for the hosting at Bradwell of ILW from Dungeness A.
BANNG is strongly opposed to:
• aqueous discharges containing radionuclides and heavy metals resulting from dissolution of FED into any UK coastal waters;
• discharges of Tritium arising from dissolution of FED into the air;
• the proposed radioactive discharges from FED dissolution at Bradwell;
• the transfer of ILW from one site to another.
BANNG believes that in the event that the NDA continues to pursue its proposals for FED dissolution and ILW transfer it should undertake a thorough consultation including public and stakeholder engagement with the communities involved on the issues of:
• dissolution of FED and full disclosure of the radioactive discharges to the environment that arise therefrom;
• full disclosure of the constituents of the silt that requires to be removed from old pipes in order to make dissolution of FED at Bradwell possible;
• the transfer of ILW from one site to another.
BANNG believes that communities that host radioactive wastes on the nation’s behalf should be properly consulted and compensated and offered partnership and packages to enhance their well-being for the long-term.
BANNG believes that there is no place for the incremental, piecemeal strategy that is being pursued by the NDA. What is required is a fully integrated, properly thought-through strategy for the management of all radioactive wastes arising in this country according to the recommendations of the first Committee on Radioactive Waste Management (CoRWM1), in which storage and possible disposal are regarded as interdependent processes.
Prepared on behalf of the Blackwater Against New Nuclear Group (BANNG) by
Barry Turner, Vice-Chair
Varrie Blowers, Secretary
31 January, 2014
(2007) first Committee on Radioactive Waste Management (CorWM1) ‘Moving Forward – CoRWM’s Proposals for Implementation’, CoRWM document 1703, February
(2013) Nuclear Decommissioning Authority, ‘Optimising the Number and Location of FED Treatment (Dissolution) Facilities in Magnox Limited – Credible Options, May
(2014) Deere-Jones, Tim, Briefing to the Nuclear Free Local Authorities Steering Committee, January
(2006) Managing our Radioactive Waste Safely – CoRWM’s recommendations to Government, November