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Comment here: https://consult.environment-agency.gov.uk/cumbria-and-lancashire/sellafield-radioactive-substances-activities-rsa-p/ See too: https://miningawareness.wordpress.com/2019/11/29/uk-environment-agency-allowing-for-increasing-radioactive-discharges-to-the-irish-sea-by-sellafield-in-violation-of-ospar-comment-deadline-1st-december-2019/

The 2006 impact assessment for the landfill, before opening, assumed that the activity limit for radioactive waste in the Calder Floodplain Landfill Segregated Area (CLESA) would be 37,000 Bq/kg, i.e. 37 thousand random shot radioactive discharges per second per kilogram (Bq/kg).

The December 2017 CLESA PCRSA based its assumptions on the 2006 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“. The current Environment Agency proposal states on p. 42 that “Units for liquid waste equivalent to LLW/ILW amended from GBq/m3 to GBq/t“. If adhered to, this means half the radiation for liquids. A GBq, Gigabecquerel, is a billion becquerels. A TBq, which appears in Sellafield documents, is a trillion becquerels. For regular pure water cubic meters (m3) is approximately one metric tonne.

Currently the amount that Sellafield (2018) gives for CLESA is 200 thousand Bq/kg – more than five times the original assumption used in the pre-opening impact study. The new proposed limit of 40 Million Bq/kg is more than one thousand times the assumption made for the 2006 impact study. If this includes radioactive materials other than tritium, then the proposed increase is even higher. According to CLESA PCRSA, 2017, Table 2, p. 19, approximately 23.4% is H3 (tritium). Thus the proposal may well be 200,000 Bq/kg of other radioactive materials plus 40,000,000 Bq/kg for tritium. This appears more likely the case, though it’s unclear. This tritium will remain radioactive for around 200 years. It is, of course, not the only radioactive material in this seaside and riverside landfill. The CLESA PCRSA Report (2017), based on Nexia (2006) and Halcrow (2006), notes that “in the absence of coastal defences, erosion of CLESA could begin in approximately 100 years’ time” (CLESA PCRSA, 2017, p.7) While the Environment Agency assume that someone will keep nature at bay for 200 years, there are other radioactive materials in this landfill, which remain radioactive far longer.

Note that for regular water, a kilogram is approximately one liter.

There is no safe dose of ionizing radiation, according to US government BEIR, other studies, and common sense. Each becquerel is a random shot that has the potential of leading to life-shortening cancers, and/or heart disease, cataracts, infertility, and disabilities.

The EU Standard for tritium in drinking water is 100 Bq per liter, which is already high. An official environmental study group for Ontario, Canada recommended that it be reduced to 20 Bq/liter: “the Council agrees with the conclusions of the BEIR VII report that there is linear dose-response relationship and no threshold for the induction of cancers by radionuclides…http://meteopolitique.com/Fiches/nucleaire/documentation/01/Nucleaire_eau-potable-Ontario-Tritium.pdf

Tritium is super-heavy hydrogen which binds to make super-heavy water. Because of this, tritiated water has different characteristics from regular water. It is heavier than regular water; it freezes and boils at different temperatures; it has other distinguishing characteristics, and, for these reasons, it can be separated from regular water. The human body is majority water, so this matters. As well, in high enough amounts, tritiated water can be a chemical poison, along with radiological hazard, for the very reason that it is heavier and thus has different behavior: https://miningawareness.wordpress.com/2019/11/08/radioactive-nuclear-waste-lies-holtec-nuclear-waste-cans-at-san-onofre-plus-tritiated-water-can-be-filtered The distinguishing characteristics suggest that it may be possible to remove tritium from other materials, as well, with a bit of thought, and perhaps innovation.

At CLESA: “Current groundwater levels below the landfill itself are not measured, but historic monitoring data is consistent with the original PCRSA which states that the regional piezometric surface beneath the landfill site is of the order of 3 to 5 m below the base of the landfill, i.e. around 3 to 4 m AOD below the base of the landfill at ~9 m AOD (Figure 6)“(CLESA 2017,, p. 28)


CLESA 2017, p. 11, Figures 5 & 6

The Environmental Agency propose to increase the limit to 40,000,000 Bq/Kg of tritium, and subsequently reduce it to 12,000,000 Bq/kg. The original impact study for CLESA assumed a 37,000 Bq/kg limit, as did the 2017 impact study.

The original PCRSA (2006) assumed that the waste at CLESA would be 37,000 Bq/kg. Currently they propose increasing the limit for tritium waste (which is radioactive) from 200,000 Bq/kg to 40,000,000 Bq/kg, and subsequently decrease again to 12,000,000 Bq/kg. This represents an over 1000 fold (x 1000) increase from the original (2006, 2017) assumptions, and an almost 200 fold (x 200)increase over Sellafields’ report (2018)!

They are burying it on the banks of the River Calder, near the coast of the Irish Sea.

They note that “This increase would enable decommissioning to progress more quickly“, so they why not just hurry up and shovel it into the River and Sea? This tritium will be radioactive for around 200 years. Instead of shoveling it directly into the Irish Sea to get shot of it, they leak and ooze it out gradually, hoping that Ireland and Norway won’t notice.

Ultimately, the Calder Floodplain Landfill Segregated Area (CLESA) waste will need to be dug up and moved, so why not package it properly and put it in a proper building in the first place? Even if it is not eroded within 200 years, other radioactive materials will still be radioactive when it does erode. How much is going into the aquifer in the interim period?

A 2008 report notes that the waste dump is in the River Calder Floodplain: “CLESA monitoring programme: We are assessing a review of the environmental monitoring programme for the first three months of operation of the Calder Floodplain Landfill Segregated Area (CLESA), which is used to dispose of high volume low-level radioactive waste on the Sellafield site. Sellafield Ltd are only permitted to use the bottom section of the landfill at present. This should provide capacity for another 2 years. We expect Sellafield Ltd to submit an application to dispose of waste along the side walls, which will more than double the available space, later this year.” (“Sellafield Ltd, LLWR at Drigg and UKAEA Windscale, West Cumbria Sites Stakeholder Group, Quarterly Report for 1 Jan to 31 Mar 2008“: p. 7)

The UK Environment Agency proposal is to increase tritium (H3) in waste levels to 4.0E+04Bq/g [40,000 Bq/g] and subsequently 1.2 E+04 Bq/g [12,000 Bq/g]. This is 40,000,000 Bq/kg, and then 12,000,000 Bq/kg – they apparently aim to make it seem much smaller.

[Recall that 1000 grams (g) is 1 kilogram (kg)]

The Environment Agency report says: “We have decided that we could permit an increase in the tritium limit for disposals in CLESA landfill to an average consignment limit of 12,000Bq/g, whilst ensuring that the environment and people are protected. This increase would mean decommissioning could progress more quickly. We plan to implement the changes to the limits and conditions Sellafield Ltd proposed to allow greater flexibility in the disposal of waste containing tritium at CLESA once Sellafield Ltd has received confirmation that it is not required to make a Euratom Article 37 submission, or, if it is, that the Department for Business Energy and Industrial Strategy (BEIS) and Sellafield Ltd have received a positive opinion that the discharges will not affect Member States from the EC on an Article 37 submission“. (P. 5) “Environment Agency Draft Decision Document 07/10/2019 Sellafield Ltd Application: EPR/KP3690SX/V009 https://consult.environment-agency.gov.uk/cumbria-and-lancashire/sellafield-radioactive-substances-activities-rsa-p/supporting_documents/Sellafield%20Ltd%20RSA%20permit%20draft%20decision%20document.pdf
Executive Summary, p. 3: https://consult.environment-agency.gov.uk/cumbria-and-lancashire/sellafield-radioactive-substances-activities-rsa-p/supporting_documents/Sellafield%20Ltd%20RSA%20permit%20summary%20document.pdf

From the EA draft: “CLESA tritium limit
68. Sellafield Ltd applied to include a nuclide-specific concentration limit for tritium (H-3) of 1.0E+05Bq/g taken as an average across each consignment load. This was supported by a number of documents. However, following detailed discussion on these documents and informal feedback on this proposal, Sellafield Ltd revised its application to change the concentration limit for tritium (H-3) to 4.0E+04Bq/g and subsequently 1.2 E+04Bq/g. This increase would enable decommissioning to progress more quickly…
“. (p. 27) “Environment Agency Draft Decision Document 07/10/2019
Sellafield Ltd Application: EPR/KP3690SX/V009
https://consult.environment-agency.gov.uk/cumbria-and-lancashire/sellafield-radioactive-substances-activities-rsa-p/supporting_documents/Sellafield%20Ltd%20RSA%20permit%20draft%20decision%20document.pdf

The 200 Bq g-1, given below, is the same as 200,000 Bq/kg
From the Sellafield “Monitoring Our Environment“, 2018 report:
25 Historically, contaminated soil arising at Sellafield from construction and excavation was disposed of at permitted landfill sites on the Sellafield site. Only one of these sites, CLESA, is now permitted. The previous landfill sites are now in closure and aftercare status. CLESA received 2,300 m³ in 2018. These disposals are included in the Site’s Environmental Permit, which includes a specific activity limit of 200 Bq g-1, above which waste has to be disposed of at the LLWR as low level radioactive waste.

Disposals made under the terms of Waste Disposal or Waste Management Licences
26 Radioactive wastes (including hazardous radioactive wastes) were historically disposed to the LLWR, now managed by LLWR Ltd. Calder Landfill Extension Segregated Area (CLESA) is permitted to take a range of Very Low Level Radioactive Wastes (VLLW) / Low Active – Low Level Waste (LA-LLW), such as concrete, soil and stones with a specific activity limit of 200 Bq g-1. Other LA-LLW and VLLW wastes (including hazardous wastes) are sent to off-site specified facilities. Where appropriate, some wastes arising on the site from both radiologically controlled areas and “non-active” areas, are carefully monitored and assessed (for example via intrusive sampling) to confirm that they are not radioactive. These activities are carried out in accordance with the UK Nuclear Industry Guide1. Such wastes are ‘Out of Scope’ under the Environmental Permitting Regulations. All wastes assessed as ‘Out of Scope’ under the Environmental Permitting Regulations 2016, as well as wastes deemed to be clean, are sent for disposal off-site as controlled wastes (paragraph 31).
https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/847946/Monitoring_Environmental_Discharges_2018__3_.pdf

THEY SHOULD NOT BURY THE WASTE. To call it an “engineered facility” is a gross abuse of the meaning of these words. They mean things like putting a plastic tarp, and clay.
Disposals by burial in an engineered facility on the site
392. The Sellafield RSA environmental permit includes disposals at Sellafield Ltd’s on-site CLESA disposal facility. Sellafield Ltd initially submitted a request to increase the specific tritium (H-3) disposal limit for CLESA to 1.0 E+05Bq/g taken as an average across each consignment load. Following discussions with the Environment Agency, this was subsequently revised to change the concentration limit for tritium (H-3) to 4.0E+04Bq/g and then to 1.2E+04Bq/g.
” (pp.80-81 Environment Agency Draft Decision Document 07/10/2019 Sellafield Ltd Application: EPR/KP3690SX/V009 https://consult.environment-agency.gov.uk/cumbria-and-lancashire/sellafield-radioactive-substances-activities-rsa-p/supporting_documents/Sellafield%20Ltd%20RSA%20permit%20draft%20decision%20document.pdf )

This is the “engineered facility” WCS in arid west Texas, USA. CLESA is on the waterfront. Both are unacceptable and will eventually need to be dug up.

THIS REMOVAL OF THE WORD LEACHATE SEEMS WORRISOME, as does almost everything about this proposal:
Some excerpts from the EA proposal regarding CLESA:
529. The word ‘leachate’ has been removed from the paragraph relating to CLESA of CEAR 3.2.5(a), so that the requirement applies to everything in the environmental monitoring programme. This is in line with Sellafield Ltd’s proposal.

Review of CEAR requirement 4.2.2 part 2 paragraph 1
530. Currently, Sellafield Ltd is required to submit detailed waste return information (waste quantity and type) for the CLESA landfill each quarter. It then submits the same level of detail on a separate form annually. We agree with the proposal to remove the requirement for quarterly waste returns as they add little benefit to regulating this facility. The requirement to submit the detailed information annually will remain. The existing requirement to submit annual summary information in CEAR proforma 7 also remains unchanged.

Review of CEAR requirement 4.2.2 part 2 paragraph 3
531. Sellafield Ltd has proposed amending the wording for condition 4.2.2 part 2 paragraph 3 that covers the environmental monitoring programme from:

(e) any positive result which exceeds the mean plus 3 standard deviations of the previous 12 results shall be highlighted and, as far as reasonably practicable, an explanation shall be provided for any such elevated value.

(f) Any result, where the criteria in (e) cannot be applied (due to a lack of previous results), which exceeds three times the expected background value or twice the limit of detection in cases where the expected background is limit of detection, shall be highlighted and, as far as reasonably practicable, an explanation shall be provided for any such elevated value.

to:
(e) any positive result that exceeds the criteria agreed in writing with the Environment Agency and, as far as reasonably practicable, an explanation shall be provided for any such elevated value.

532. The reason for these changes is due to ongoing discussion between the Environment Agency and Sellafield Ltd regarding notification of results that exceed the above criteria. The current approach is not working because we are receiving notifications that are not of interest to us.

533. Since the variation application, we and Sellafield Ltd have subsequently agreed new wording of the CEAR that, if accepted after we have carried out an internal review, will represent a generic change to the CEAR. Until this new wording is finalised, we have taken the decision to reject the wording suggested by Sellafield Ltd in its variation application. The original wording of the CEAR will, therefore, remain for the time being.

Review of CEAR requirement 4.2.2 part 2 paragraph 4
534. The proposal to add the following bullet point into CEAR requirement 4.2.2 part 2 paragraph 4 is accepted with minor amendments. We have agreed the minor amendments with Sellafield Ltd by e-mail as part of the determination of this variation application.

any positive result in the Calder Floodplain Landfill Extension – Segregated Area (CLESA) monitoring results which exceeds the control, action or trigger levels specified in the Environmental Monitoring Programme (Site Operational Phase) for Calder Landfill Extension Segregated Area and, as far as reasonably practicable, an explanation shall be provided for any such elevated value. Where no explanation is available for any such exceedance, Sellafield Ltd shall inform the Environment Agency to that effect.

535. Including all CLESA monitoring under CEAR requirement 3.2.5(a) above makes it necessary to include this new requirement to inform the Environment Agency ‘without delay’ when any of the control, action or trigger levels are exceeded. The environmental monitoring programme (site operational phase) for Calder Landfill Extension Segregated Area contains a set of contingency actions to be taken if any control, action or trigger levels are exceeded.

Review of CEAR requirement 4.2.2 paragraphs 8, 26, 27, 28

536. These CEAR requirements state that Sellafield Ltd must notify us regarding specified circumstances.

537. Sellafield Ltd proposes that we combine current requirements 8, 26, 27 and 28 into a single requirement. We have decided that this proposal is acceptable and CEAR requirement 4.2.2 (8, 26, 27, 28) will be consolidated into a single CEAR requirement as paragraph 8. This will cover notifications regarding plant modification proposals, diversion of discharges from sea line 2 to sea line 3, and pumping of lagoon liquor to discharge via the factory sewer in exceptional storm conditions.

Review of CEAR requirement 4.2.2 part 2 paragraph 9

538. Sellafield Ltd has proposed removing the requirement for an annual CLESA leachate report. The current CEAR requirement is for Sellafield Ltd to submit CLESA leachate quality and level data quarterly, six-monthly and annually. This is in addition to the CLESA annual report (CEAR 4.2.2(9 a-e)). Including the new requirement to inform the Environment Agency ‘without delay’ if a control, action or trigger level (specified in the environmental monitoring programme – see above) means that there is no longer any need for Sellafield Ltd to report the raw data any more regularly than in the annual report. The requirement to report the leachate data remains, but only as part of the annual report as required by CEAR 4.2.2(9)(a-e). Any exceedences that require action to be taken will be flagged up and acted on at the time they occur“. (p. 137-138: Environment Agency Draft Decision Document 07/10/2019
Sellafield Ltd Application: EPR/KP3690SX/V009 https://consult.environment-agency.gov.uk/cumbria-and-lancashire/sellafield-radioactive-substances-activities-rsa-p/supporting_documents/Sellafield%20Ltd%20RSA%20permit%20draft%20decision%20document.pdf )

International Standards tritium drinking water: https://www.nrc.gov/docs/ML1029/ML102990104.pdf (pdf page 15)

CLESA is in the Calder Hall flood plain “Sellafield Ltd, LLWR at Drigg and UKAEA Windscale, West Cumbria Sites Stakeholder Group, Quarterly Report for 1 Jan to 31 Mar 2008” Stakeholders web site: http://wcssg.co.uk/wp-content/uploads/2014/10/ea-report-030408-final1.pdf

CLESA PCRSA: CLESA erosion 100 years time, p. 7, pdf p. 18:
Tritium p. 30 pdf

CLESA Report: “CLESA PCRSA
Review Report December 2017 Ref: ESR197 Document Ref: 60493376/MARP003
Prepared for: Sellafield Ltd Prepared by: AECOM
https://consult.environment-agency.gov.uk/cumbria-and-lancashire/sellafield-rsa-major-permit-review/supporting_documents/10.%20MARP003_CLESA%20PCRSA%20Updated%20Report%206.12.17.pdf-1

Sellafield discharges: https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/847946/Monitoring_Environmental_Discharges_2018__3_.pdf

Deadline is midnight in the UK. However, you can send it late by email, whether it is formally accepted or not, we don’t know.

Consultation questions

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?

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?

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?

4. Does the proposed tritium limit for disposals in CLESA raise any concerns for you? If so, what are these concerns?

5. Is there anything that is inaccurate or missing in the draft decision document? If so, please provide details.

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.

7. Any other comments on the proposed permit change (variation)?
https://consult.environment-agency.gov.uk/cumbria-and-lancashire/sellafield-radioactive-substances-activities-rsa-p/supporting_documents/Sellafield%20Ltd%20RSA%20permit%20draft%20decision%20document.pdf

Excerpts/Diagrams from CLESA Report: “CLESA PCRSA
Review Report December 2017 Ref: ESR197 Document Ref: 60493376/MARP003
Prepared for: Sellafield Ltd Prepared by: AECOM

















https://consult.environment-agency.gov.uk/cumbria-and-lancashire/sellafield-rsa-major-permit-review/supporting_documents/10.%20MARP003_CLESA%20PCRSA%20Updated%20Report%206.12.17.pdf-1

EMPHASIS OUR OWN THROUGHOUT.
Disclaimer: Always check our work, as well as anyone else’s work. This was checked many times, but errors can happen, especially as we had little notice, and as the nuclear industry, which seems to include the UK Environment Agency, apparently makes muddling information their full-time job, especially changing notation. Or perhaps this merely reflects their state of mind – muddled that is.