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All operating UK Nuclear Reactors, but Wylfa, belong to 85% French government owned EDF.
UK NPS wikipedia http://en.wikipedia.org/wiki/Nuclear_power_in_the_United_Kingdom
(NB: Nuclear Power Plants often have two or more reactors.)

According to the SEPA Consultation documents, majority(85%) French government owned EDF wants to “combine similar waste arsings from other EDF Energy stations” at Hunterston B in Scotland. Of course, they meant to say “arisings” but what a Freudian slip is “arsings”! The only honest part of the SEPA consultation is actually the request by EDF to change their name from British Energy to EDF, since it is a French government owned entity, though actually they should call it French State-owned Nuclear Energy.

Did the 55% who voted “no” to Scottish independence understand or care that by staying yoked to the nuclear UK, they were yoked to nuclear France and a small mafia-like coterie running EDF, currently led by Henri Proglio? This should have been clear from the relationships between siblings of UK government officials (Gordon Brown and Ed Davey) and EDF. Former PM Gordon Brown’s brother became head of media relations for EDF Energy in 2004 and the director of corporate communications in 2011. The head of the Dept. of Energy (DECC) Ed Davey’s brother Henry did work for EDF during their takeover of British Energy. http://stopnuclearpoweruk.net/content/new-energy-secretarys-appointment-underlines-unhealthy-relationship-between-government-and http://en.wikipedia.org/wiki/Andrew_Brown_(media_strategist) If that doesn’t make it clear to everyone, reading the EDF consultation by the so-called Scottish EPA, makes it abundantly clear. Furthermore, you don’t have to scratch the surface of history very deeply to see what grief French elites have caused Scotland, England, Ireland, France, and everywhere else they have set foot for almost one thousand years and maybe more.

Some have suggested that the E stands not for Electricity but for Espionage, due to evidence-based allegations that EDF spied on Greenpeace, as well as another anti-nuclear activist (Stephane Lhomme) in France. EDF was also reportedly seeking information on activists in the UK, Spain and Belgium: http://business-humanrights.org/en/in-lawsuit-against-edf-in-france-greenpeace-alleges-firm-employed-security-company-to-spy-on-critics#c39262

While looking at the questions asked by the Scottish EPA (SEPA) for their Oct. 3rd Consultation, we noticed that there is actually a secondary consultation involved. http://www.sepa.org.uk/about_us/consultations.aspx, This second consultation is regarding Appendix 8, which seems to be bureaucratic nonsense-double speak designed to enable the request of EDF to be better carried out. Disgustingly typical of so-called “regulators” in the US and UK, SEPA seems to think that it exists NOT to regulate the nuclear industry but to “facilitate” its activities. At one point Appendix 8 says that waste must be returned after “processing” and then it seems to think not! Not reimporting may help explain one way that EDF and SEPA think that they will export Intermediate Level Waste and magically turn it into Low Level Waste! The other way is that it will go into the air and water at the processing location (e.g. Baltic Sea or Mississippi River).

If the current Scottish government is anti-nuclear and pro-Scotland and Scottish people, as they claim, then they need to do a serious house-cleaning of SEPA. SEPA bureaucrats need to shape up or ship on out to France. Qualified, intelligent, honest and honourable people can be found to take their place. True Scots would volunteer to do this job right. Why pay people to do it wrong? If those in SEPA are qualified or intelligent, then they are dishonest and dishonourable.

Importing nuclear waste from elsewhere is not good for Scotland and exporting it onto other people is dishonourable and also carries a risk for Scots at home, as well as those abroad, in the diaspora.

In whose mind is it sane to have run the Cherokee and other Indian Nations off their lands; run Scots off their lands and put them on Cherokee lands, and then dump nuclear waste on top? That is the long-view of what is going on! This is dishonourable and it is wrong on the US end and on the Scots end. Obviously it is also wrong on the French, UK, and German government ends, but who would expect better of these old imperialist powers?

This SEPA consultation on the EDF requests should never have been held. An intelligent, honest SEPA would be able to see straight up what this EDF request is about and put a stop to it without “consultation”.

The first questions asked by SEPA involve requests by EDF for what appears essentially deregulation of their activities involving nuclear waste and an attempt to use Scotland for a nuclear waste import-export site. A narrow reading is that this would involve the 15 nuclear reactors operated by EDF in the UK. A broad reading could mean an additional 67 plus French nuclear reactors (nuclear power plants often have more than one reactor).
French NPS wikipedia
http://en.wikipedia.org/wiki/Nuclear_power_in_France

There are also additional EDF reactors proposed or under construction in the UK, France, and elsewhere. EDF Energy in the UK is a fully owned subsidiary of EDF SA. Thus the 4 nuclear reactors in Scotland- two at Hunterston B and two at Torness- are owned by 85% French government owned EDF (Électricité de France). EDF also owns 11 other nuclear reactors in England, and 58 operating and 9 undergoing decommissioning in France.
For EDF ownership
1. French State : 84.48 %
2. Institutional : 13.10 %
3. EDF workers: 2.39 %
4. EDF owned (autocontrole) : 0.03 % http://fr.wikipedia.org/wiki/Électricité_de_France Nuclear Energy represents 79.6% of EDF energy production in 2011, from its 58 nuclear reactors operating in France and 15 in the UK. http://fr.wikipedia.org/wiki/Électricité_de_France

Responses to the consultation should be sent in writing to the address below no later than 3 October 2014. The Registrar Scottish Environment Protection Agency Angus Smith Building Parklands Avenue Eurocentral Holytown North Lanarkshire ML1 4WQ Or registry.angussmith@sepa.org.uk

Below, in bold, are the questions asked by SEPA. Our commentary is in brackets. Notice that the EDF request and SEPA consultation misleadingly start with Low Level Waste, but then jump to Higher Level-Intermediate level waste. There are multiple EDF requests in the original EDF documents. One involves import of unidentified types of radioactive waste from other EDF Energy power stations. One involves Low Level Waste export and one involves Intermediate Level Waste export. A request for import and a request for exports translates into an overall picture of using Hunterston B and Torness as EDF import-export facilities or staging areas. EDF says that this will “help EDF Energy implement centralised approach to the management of radioactive waste“, which further clarifies their intent. The two Scottish facilities would be used for “interim storage“, “loading” and “onward transfer.” This corresponds to the French ideal of centralising everything. As clear on maps, Hunterston B is conveniently located on the Irish Sea and Torness on the North Sea. The only possible interpretation is that EDF wants to make these two Scottish locations into radioactive waste import-export hubs; staging areas.

First SEPA Question:
Question: Do you have any comments on the proposed changes to the Authorisation for disposal of Low Level Wastes from Hunterston B and Torness, in particular the removal of specified destinations?” (p. 9)

EDF has applied to allow the disposal of low level radioactive wastes (LLW) to facilities which are not specified in the current Authorisations but which have appropriate permits to accept the waste. These facilities may not be based in the UK.

Historically, SEPA’s Authorisations issued to NLS have specified the site of destination for any radioactive waste removed from the NLS. Any proposed changes or deviation from the specified route required Authorisation Holders to apply to SEPA for a variation to their Authorisation. Such changes were typically deemed to be substantial by SEPA and therefore required public consultation. This delayed the opening up of the new disposal routes for the Authorisation Holder and resulted in significant administrative burden on both the Authorisation Holder and SEPA….” (p. 9) http://www.sepa.org.uk/about_us/consultations.aspx, http://www.sepa.org.uk/about_us/idoc.ashx?docid=5d0fca3f-9f32-4cc5-884b-b66817f708be&version=-1 [Notice that SEPA’s sees doing its job as a “burden” to itself and to EDF. Our conclusion – get rid of the lazy SEPA workers! Their JOB is to regulate. Mention is made on p. 9 of the “Transfrontier Shipment of Radioactive Waste Regulationshttps://www.gov.uk/radioactive-waste-spent-fuel-or-sources https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/296882/LIT_9004_2c31f1.doc Type of radionuclides and activity levels are required on these forms. Where it is being shipped is required. So, why can’t SEPA continue to require this information? This appears an effort to deregulate and allow the waste to be spread in landfills throughout the UK and the world. It is important to track and monitor all radioactive waste!]

WHILE EDF HAS ASKED FOR PERMISSION TO EXPORT LOW LEVEL AND INTERMEDIATE LEVEL WASTE, SEPA SPEAKS OF HIGHER ACTIVITY RADIOACTIVE WASTES, “INCLUDING INTERMEDIATE LEVEL WASTE!” IS SEPA GIVING MORE THAN EDF ASKED FOR? DOES THIS THEN INCLUDE SPENT FUEL?
Second SEPA Question:
Question: Do you have any comments on the proposed changes to the Authorisation for the disposal of higher activity radioactive wastes from Hunterston B and Torness?

EDF have applied to allow the disposal of higher active radioactive wastes (HAW), including Intermediate Level Waste (ILW), to a number of named facilities as well as facilities that might develop in the future, both within and outside of the UK. This is a similar approach to that adopted for LLW.

Historically, SEPA has adopted a different approach to authorising ILW disposals by specifying the waste type and the destination site as well as often imposing activity limits on the waste that could be disposed of. Decisions to authorise such disposals were taken on a case-by-case basis.

Disposal of this type of waste are subject to Scotland’s Higher Activity Radioactive Waste Policy, which was published by Scottish Government in 2011. The policy is discussed further in section 6.2.2.” (pp. 9-10) http://www.sepa.org.uk/about_us/consultations.aspx, http://www.sepa.org.uk/about_us/idoc.ashx?docid=5d0fca3f-9f32-4cc5-884b-b66817f708be&version=-1
[Our note: In 6.2.2 SEPA states some confusing nonsense in an apparent double standard attempt to slither out of the fact that the Scottish Higher Activity Radioactive Waste Policy is supposed to involve proper above ground storage and not burial: “Although the HAW Policy has a presumption that HAW arising in Scotland will be stored or disposed of in a facility near the site where it arose and near to the surface, it does not preclude HAW leaving the site where it arose for treatment, where that treatment will result in the waste being in a form which will facilitate it future management and where that treatment represents BPM.” (p. 16)]

EDF itself notes that currently Radioactive waste can only be removed from Hunterston (and Torness) to named “specified” locations. EDF is requesting that they be able to move Low Level Radioactive Waste from Hunterston (and Torness) to any place “authorised to receive it for treatment and disposal“. Due to the dustbin category of UK nuclear waste, it can now disappear into landfills in the UK (including Scotland), as well as abroad.

But, additionally, permission is sought to import non-specified types of radioactive waste and to transfer Intermediate Level Waste off-site for treatment such that its final waste form can be “categorised as Low Level Waste and is suitable for disposal.
These possible sites include:
UK sites for EDF ILW export
image
Incinerator, Hythe UK,
Metal treatment facility, Lillyhall, UK
Waste treatment amd reprocessing site, Winfrith UK
Incinerator, Elsmere Port, UK,
Incinerator, Slough, UK,
Incinerator, Dessel, Belgium
Metal treatment facility Krefeld Germany
Incinerator and Metal Treatment Facility, Nykoping, Sweden
Incinerator and Metal Treatment Facility, Tennessee, USA,
Other UK incinerators
Other overseas incinerators and metal treatment plants
Any UK and overseas radioactive treatment facilities which become available at a future date
“. http://www.sepa.org.uk/about_us/consultations.aspx; http://www.sepa.org.uk/about_us/idoc.ashx?docid=ce7bb05f-0654-40da-aaf1-e5605a820ab1&version=-1 [It does not say where it is suitable for disposal, but this could include Scottish landfills. That the type of imported radioactive waste seems unspecified leaves open the possibility of import of High Level Nuclear Waste, but since it could not be exported it would be stuck in Scotland. The request involves import of radioactive waste and export of Intermediate Level Waste. Having read the EDF documents at least 10 times, it is clear: EDF REQUESTS IMPORT OF UNIDENTIFIED TYPES OF RADIOACTIVE WASTE FROM OTHER EDF ENERGY STATIONS TO HUNTERSTON B AND TORNESS AND EXPORT FROM HUNTERSTON B AND TORNESS OF BOTH LOW LEVEL AND INTERMEDIATE LEVEL WASTE. Les salopards d’EDF nous prennent pour les cons – EDF thinks that we are idiots, it seems. They think we are illiterate, whereas Scots have long prized literacy. EDF can give us their damned documents in French and we can read them too! EDF=Maudit salopards! EDF Dirty MF!]

SEPA Question 3:
Question: Do you have any comments on the proposed changes to remove the limits and physical/chemical descriptors from the radioactive waste disposed of by transfer from the Authorisation for Hunterston B and Torness?
4.2.3 Removal of Limits and Physical/Chemical Descriptors
EDF has applied to remove the authorised limits relating to radionuclide and activity as well as the specification of physical and chemical characteristics for radioactive wastes being disposed of by transfer to another facility…
” (p. 10) http://www.sepa.org.uk/about_us/consultations.aspx, http://www.sepa.org.uk/about_us/idoc.ashx?docid=5d0fca3f-9f32-4cc5-884b-b66817f708be&version=-1 [The type of radionuclides and radioactive “activity” is the most important aspect. It is important to monitor types of radionuclides and activity levels at all times. What else can this request be called but deregulation? It is outrageous. It is “n’importe quoi” in the French sense which is much more pejorative than English “anything goes” and implies crazy, out of control, antisocial behaviour. In short, “n’importe quoi” perfectly defines the out of control nuclear industry and the out of control French elites who run EDF and AREVA.]

SEPA Question 4:
Question: Do you have any comments on the proposed changes to the Authorisation for the acceptance of radioactive wastes at Hunterston B and Torness from other EDF Energy stations?
4.2.4 Arrangements to Receive Radioactive Waste from Other Premises

EDF has applied to allow the receipt of radioactive waste on to both stations for interim storage and onward disposal. These wastes will have arisen at other EDF Energy nuclear power stations, and the intention is to allow for the accumulation of economic loads prior to disposal.

The accumulation of radioactive waste at an NLS is exempted from control under RSA93, and hence is outwith SEPA’s control… The subsequent disposal of radioactive wastes received from other premises from the NLS is, however, a matter for SEPA and the Authorisation.” (p. 10) http://www.sepa.org.uk/about_us/consultations.aspx, http://www.sepa.org.uk/about_us/idoc.ashx?docid=5d0fca3f-9f32-4cc5-884b-b66817f708be&version=-1
[Making Scotland into a radioactive import-export hub is dangerous for those in Scotland and abroad. It is unethical and unfair. Scotland actually is a net energy exporter. Why should it be importing nuclear waste from elsewhere either to keep in Scottish landfills or to re-export? EDF itself states in the consultation documents that “the risk to the environment will be reduced to an acceptable level.” (p. 9) An acceptable level to whom? This is an unnecessary risk. Any risk is thus unacceptable. The only beneficiary is the French government-EDF]

SEPA Question 5:
Question: Do you have any comments on the proposal to change the name appearing on the front page of the Authorisation for Hunterston or Torness?
4.2.5 Proposal to Update the Name of the Authorisation Holder

EDF has applied to change the name of the Authorisation Holder from British Energy Generation Limited to EDF Energy Nuclear Generation Limited. This will reflect the change in company name although not company number discussed in section 4.1. The proposed change would remove any potential confusion regarding the identity of the Authorisation Holder and improve EDF’s corporate branding of all their permits.” (p. 11)
[Our comment: Yes, please hurry up and change the name to reflect the truth – this is a French government owned company. Calling it British Energy is deceptive. However, it should be more clearly called French State Owned Nuclear Energy or French Government Owned Nuclear Energy.]

SEPA Question 6:
Question: Do you have any comments on the proposed changes to the Authorisation, in particular the importation of standard conditions from the SEPA template for nuclear Authorisations?
Since the extant Authorisation was issued SEPA has evolved its standard template of schedules of conditions and limitations for use in civil nuclear site RSA93 Authorisations. A copy of this template is attached as Appendix 8….” (p. 11) “SCOTTISH ENVIRONMENT PROTECTION AGENCY, RADIOACTIVE SUBSTANCES ACT 1993, Application by EDF Energy Nuclear Generation Limited for Changes to the Authorisation covering the disposal of Radioactive Wastes from Hunterston B and Torness Power Stations, CONSULTATION DOCUMENT FOR DISCRETIONARY CONSULTEES AND THE PUBLIChttp://www.sepa.org.uk/about_us/idoc.ashx?docid=5d0fca3f-9f32-4cc5-884b-b66817f708be&version=-1

Appendix 8 appears to be a sort of 30 pages of consultation within the consultation! NOTE THAT LLW HAS RADIOACTIVE CONTENT NOT EXCEEDING 4 GBQ PER TONNE OF ALPHA OR 12 GBQ PER TONNE OF BETA/GAMMA.
THAT IS 4 MILLION BECQUERELS PER KG OF ALPHA RADIATION OR 12 MILLION BECQUERELS PER KG OF BETA-GAMMA. It is not clear if these amounts are either/or, or if they are and/or.

Some interesting points in Appendix 8:
RS-S-007 Version8

“LLW” means radioactive waste having a radioactive content not exceeding four gigabecquerels per tonne (GBq/te) of alpha or 12 GBq/te of beta/gamma activity;
Page 5 of 30

3)(a) In determining whether particular means are the “best practicable” for the purposes of this Authorisation, the Authorisation Holder shall not be required to incur expenditure whether in money, time or trouble which is, or is likely to be, grossly disproportionate to the benefits to be derived from, or likely to be derived from, or the efficacy of, or likely efficacy of, employing them, the benefits or…..”
(emphasis our own)
RS-S-007 Version8
Page 6 of 30

Disposal
2.1.1 The Authorisation Holder shall use the best practicable means to minimise the volume of and the total radioactivity in radioactive waste produced.
2.1.2 For each of the relevant waste types and disposal routes specified in Table 3.1, the Authorisation Holder shall use the best practicable means to:
2.1.2.1 minimise the radioactivity of gaseous and aqueous radioactive waste disposed of by discharge to the environment; and
2.1.2.2 dispose of radioactive waste at times, in a form, and in a manner so as to minimise the radiological effects on the environment and members of the public.

RS-S-007 Version8
Page 9 of 30

2.2.3.1 achieving and maintaining an optimal level of protection of the environment and the population;
RS-S-007 Version8
Page 10 of 30

….

[Related: https://www.gov.uk/national-arrangements-for-incidents-involving-radioactivity-nair%5D
….
The Authorisation Holder shall discharge radioactive aqueous waste to the environment only during the interval commencing one hour after high-tide and ending four hours after high-tide.
….
5.2 Discharges exceeding a Quarterly Notification Level

5.2.1 If, in any quarter, the activity in radioactive aqueous waste discharged of any radionuclide or group of radionuclides specified in column 1 of Table 5.2 exceeds the relevant Quarterly Notification Level (where specified) in column 3 of that table, the Authorisation Holder shall not later than 14 days from making the record which demonstrates such an excess, provide SEPA with a written submission which includes:

5.2.1.1 details of the occurrence;
5.2.1.2 a description of the means used to minimise the activity of radioactive aqueous waste discharged;
5.2.1.3 a review of those means having regard to paragraphs 2.1.1 and 2.1.2;
RS-S-007 Version8
Page 18 of 30
….
RS-S-007 Version8
Page 19 of 30
5.4 Measurement of total alpha emitting radionuclides

5.4.1 For the purposes of demonstrating compliance with the limitations and conditions of this Authorisation relating to “total alpha emitting radionuclides”, the Authorisation Holder shall measure the total alpha activity by using:

[NOTE: Consider the need to specify the method. Set out as per 4.4.1.]

[NOTE: The method for measurement only needs to be specified if a total alpha limit has been set.]

5.5 Environmental Harm

5.5.1 Other than as specifically permitted or limited by any condition of this authorisation, discharges shall not have a significant adverse impact on, or cause pollution of, the water environment.
RS-S-007 Version8
Page 19 of 30
” (Emphasis our own)
http://www.sepa.org.uk/about_us/idoc.ashx?docid=6e9eeac4-1b46-44da-b14c-ddb2ef6aa47c&version=-1
[OUR NOTE: TOTAL ALPHA LIMIT DOES NOT APPEAR SET BY THIS DOCUMENT ]

We attach a few interesting pages from Appendix 8. The green highlight is in the original and seems to mainly be an attempt at deceptive double-speak. The yellow highlight and red underline are our own.
SEPA EDF p. 14
SEPA EDF App 8 p. 22
SEPA EDF App 8 p. 24
SEPA EDF App 8 p. 25
SEPA EDF App 8 p. 26
SEPA EDF App 8 p. 27
SEPA EDF App 8 p. 28
SEPA EDF App 8 p. 29
Appendix 8http://www.sepa.org.uk/about_us/idoc.ashx?docid=6e9eeac4-1b46-44da-b14c-ddb2ef6aa47c&version=-1

We apologize to donkeys and donkey lovers for our use of Âneries in that donkeys (asses) are smart and the nuclear industry is stupid. But, the combination of Arsings and Âneries was too tempting. The full EDF quote from the consultation documents: “Allowing waste to be received at Hunterston B. Power station would enable EDF Energy to combine similar waste arsings from other EDF Energy stations to form a joint consignment…