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burying nuclear waste, Calder Flood Plain, Calder Floodplain Landfill Segregated Area, cancer, clean water, CLESA, corruption, dangers of nuclear, democracy, Drigg, EA Consultation, environment, Euratom, H-3, impact study, Irish Sea, landfill, leachate, low level waste, nuclear, nuclear landfill, nuclear safety, nuclear waste, nuclear weapons, nuclide-specific concentration limit, radioactive discharges, radioactive waste, risk management, River Calder, Sellafield, super heavy water, tritiated water, tritium, UK, UK Environment Agency, West Cumbria, Windscale
Have your Say:”Sellafield Radioactive Substances Activities (RSA) Permit – Draft Decision” Consultation link: https://consult.environment-agency.gov.uk/cumbria-and-lancashire/sellafield-radioactive-substances-activities-rsa-p/ Deadline is today, December 1, 2019 – most likely midnight in the UK. It is possible that they may accept late submissions by email. We recommend that you complain that you were not made aware in time, if such was the case .
See references and more details here:
Sample responses to the Sellafield Consultation, to give ideas for those who are running late, are found below. Please note that we vehemently oppose all discharges of radioactive materials into the environment and believe that they should be properly packaged and stored until they are no longer dangerous. Certainly they should never be buried, especially on the seaside and riverside and a wet environment. However, what is found below has to do with increasing or decreasing discharges to the environment. The Environment Agency apparently wish to leave the door open to increases.
Sample Responses to Consultation questions
Question “1. Do you understand the proposed structure of discharge limits and levels, and how it is intended to control discharges at the site? Does the new structure (site upper and lower limits, quarterly notification levels, annual plant notification levels and monthly triggers) raise any concerns for you? If so, what are those concerns?”
Response 1: The discharge limits and levels should be compared to and aligned with Sellafield’s actual current discharges, rather than the astronomically high current authorised limits. Caesium 137 discharges to the Irish Sea have increased by 69% since 2014, while remaining at 13% of the authorised limit of 34 Trillion Bq (TBq). Furthermore, limits and monitoring need to be maintained on all radionuclides. By basing the new limits upon old limits, rather than actual discharges, you are misleading the public, and leaving the door open to enormous increases in discharges. You are removing the limits on many radionuclides which will remain radioactive in the environment for years, such as Caesium 134. There need to be limits on all radioactive substances. In some instances, Sellafield’s actual discharges have been increasing, as well. To compare to 2006 discharges, rather than recent years, is misleading and wrong. Your proposal does not appear intended to control discharges, but rather to mislead the public, as well as attempting to mislead other countries, such as Ireland and Norway. This proposal is in clear violation of OSPAR, where discharges should be reducing, rather than increasing, and should be close to zero by 2020. If you are going to continue to discharge to air and water, then you need to have Sellafield report on a frequent basis, and you need to independently monitor all discharges on a frequent basis. Limits should be per facility, as well as for the entire site. Notification is unacceptable as it does not allow punishment. Limits should be aligned with Sellafield’s actual discharges, not the current authorised limits, and aimed toward reduction, rather than leaving the door wide-open to enormous increases of discharges.
Question “2. Do the values of the proposed site (upper and lower limits), quarterly notification levels and annual plant notification levels raise any concerns for you? If so, what are those concerns?
Response 2: By comparing the discharge limits and levels to current limits, rather than Sellafield’s actual discharges, you are leaving the door wide open to enormous increases in discharges of long-lived lethal radioactive substances to air and water. In short, the limits are too high. For instance, Caesium 137 discharges to the Irish Sea have increased by 69% since 2014, while remaining at 13% of the authorised limit of 34 Trillion Bq (TBq). Your proposed “limits” appear devised to allow huge increases in discharges, rather than decreases. Sellafield’s discharges, for some radioactive materials, have been increasing, too, over the last few years. Clearly your proposal is not intended to control discharges, but rather to mislead the public, as well as attempting to mislead other countries, such as Ireland and Norway. This proposal is in clear violation of OSPAR, where discharges should be close to zero by 2020.
Question “3. Are you satisfied that the varied Sellafield permit aligns with government policy and guidance, in particular the UK strategy for radioactive discharges? If not, what are your concerns? ”
Response 3: This proposal is in clear violation of promises to reduce discharges, and hence in violation of OSPAR. Rather, it appears designed to allow enormous increases in radioactive discharges. The discharge limits and levels should be compared to and aligned with Sellafield’s actual current discharges, rather than the astronomically high current authorised limits.
By basing the new limits upon old limits, rather than actual discharges, you are misleading the public, and leaving the door open to enormous increases in discharges. You are removing the limits on many radionuclides which will remain radioactive in the environment for years, such as Caesium 134. There need to be limits on all radioactive substances discharged, if you insist upon continuing to discharge radioactive materials into the environment.
Question “4. Does the proposed tritium limit for disposals in CLESA raise any concerns for you? If so, what are these concerns? ”
Response 4: Your proposed limit of 40 million Bq/kg is in violation of the impact assessment assumption of 37 thousand Bq/kg. As well, it is unclear if this new proposal of 40 million bq/kg is in addition to the 37 thousand bq/kg or replaces it. Is the proposal 40 million Bq/kg of tritium AND 37,000 Bq/kg of other materials?
The December 2017 CLESA PCRSA based its assumptions on the amount: “The remaining ~70,000 m3 was assumed to be filled with waste corresponding to the original PCRSA fingerprint (i.e. 37 Bq/g, i.e. Table 1).” (CLESA PCRSA, 2017, p. 26). In the CLESA PCRSA they assume that “For future disposals the in-situ density was taken to be the same as the existing disposals, i.e. 2,030 kg/m3“. Thus, p. 42, of your proposal, which states that “Units for liquid waste equivalent to LLW/ILW amended from GBq/m3 to GBq/t“ – if adhered to – would mean half the radiation for liquids, if you weren’t raising the overall amount.
I am concerned about pollution of the land-based aquifers, the Irish Sea, and the potential for explosion of the landfill. After all, tritium is for more efficient detonation of nuclear weapons. Why not properly store the waste?
If speed is the grounds for nuclear waste policy, then why not simply throw it directly into the Irish Sea, rather than this deception? Clearly, it’s because you know that Ireland, Norway, and others would object to more overt dumping. You state “This increase would enable decommissioning to progress more quickly”, so then why not just hurry up and shovel it into the River and Sea? This tritium will be radioactive for around 200 years, and the landfill could erode within 100 years, if not maintained. Meanwhile it gradually pollutes the water.
Again I note inconsistency, where Sellafield (2018) gives 200,000 Bq/kg for CLESA, which is already more than five times that given in the impact studies. Now you propose to increase it again to 40 million Bq/kg, more than one thousand times the assumption of the impact study.
According to the CLESA PCRSA Report (2017), Nexia (2006) and Halcrow (2006), “in the absence of coastal defences, erosion of CLESA could begin in approximately 100 years’ time” (CLESA PCRSA, 2017, p.7)
Question “5. Is there anything that is inaccurate or missing in the draft decision document? If so, please provide details.”
Response 5: The baseline for the CLESA increase for tritium is missing. It remains unclear if the tritium increase is in addition to the current disposal baseline. It remains unclear how and why you increased the current disposal baseline, without doing a new impact assessment. More generally, you need to include the CLESA PCRSA Report, and Sellafield’s Monitoring report. Furthermore, as outlined in earlier questions, this report is misleading.
Question “6. Has any relevant information become available since we consulted on the application, or was any information missed last time that we have not provided as part of this consultation? If so, please provide details.”
Response 6: The baseline for the CLESA increase for tritium is missing. It remains unclear how and why you increased the current disposal baseline, without doing a new impact assessment. More generally, you need to include the CLESA PCRSA Report, and Sellafield’s Monitoring report. Furthermore, as outlined in earlier questions this report is misleading.
BAT best practices should not be some arbitrary economic baseline which excludes public health and environmental costs, which will create additional taxpayer and social burdens. Furthermore, you have failed to include cost of removing the waste at a future date, and the cost of protecting the landfill from erosion.
Question “7. Any other comments on the proposed permit change (variation)? ”
There needs to be consistency in your report and that of Sellafield’s discharges. You use GBq (a billion becquerels) and Sellafield reports in TBq (trillion Bq). You need to drop the scientific notation, and write out the actual numbers. If you insist upon such enormous discharges, then you need to either use TBq, like Sellafield, or write out the entire number or both. The discharge limits and levels should be compared to, and aligned with, Sellafield’s actual current discharges, rather than the astronomically high current authorised limits. Furthermore, limits and monitoring need to be maintained on all radionuclides. By basing the new limits upon old limits, rather than actual discharges, you are misleading the public, and leaving the door open to enormous increases in discharges. You are removing the limits on many radionuclides which will remain radioactive in the environment for years. There need to be limits maintained for all radioactive substances. In some instances, Sellafield’s actual discharges have been increasing, too. To compare to 2006 discharges, rather than recent years is misleading and wrong. Clearly your proposal is not intended to control discharges, but rather to mislead the public, as well as attempting to mislead other countries, such as Ireland and Norway. This proposal is in clear violation of OSPAR, where discharges should be reducing, rather than increasing, and should be close to zero by 2020.
Waste should not be buried, especially on the river and sea, as it will have to be removed and properly packaged, so why not do it properly in the first place? Store it in proper containment in a proper building.
Mining Awareness + 