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TELL THE GOVERNMENT TO HALT GDF PLANS - In Answer to CONSULTATION - #GDFOFF

Updated: May 4, 2023

Dear Friends


Radiation Free Lakeland have just put together a reply to the Government's consultation on the nuclear dump plans. You don't have to write a long reply to all their (loaded) questions. The main thing is to say that the GDF and Near Surface plans are too dangerous and that the Government should think again. Please do use the below for inspiration for your own replies to the consultation which can be found here https://www.gov.uk/government/consultations/managing-radioactive-substances-and-nuclear-decommissioning


Your reply does not need to be long - even a sentence or two explaining why the Government should halt GDF plans would be good - Email your reply to the consultation here: RSNDPolConsult@beis.gov.uk




Managing radioactive substances and nuclear decommissioning

Consultation by: Department for Energy Security and Net Zero

Published 1 March 2023


Notes from Radiation Free Lakeland sent by email to:

RSNDPolConsult@beis.gov.uk

3rd May 2023

(address supplied)



Radiation Free Lakeland are a volunteer civil society group who formed in 2008 as a response to the Managing Radioactive Waste Safely’s (now RWM/NWS) ‘steps to Geological Disposal’ which were halted by Cumbria County Council in 2013.. RaFL’s focus is nuclear safety.


Introduction: RaFL do not recognise the validity of this consultation for the following reasons:


a) TIMING - It is taking place at a time when the most expedient ( proximity to Sellafield ) target area for nuclear waste disposal is undergoing the upheaval of Local Government Organisation.

b) CRONYISM - The NDA and Nuclear Waste Services are being advised on “Investigation Techniques,” “Construction” and “Costings for Scenarios” including “co-location” of a Geological Disposal Facility (for High Level Wastes) and Near Surface Disposal (for Intermediate Level Wastes) by the CEO of West Cumbria Mining. Mark Kirkbride’s coal mine, now approved by Government, lies directly between the target areas of Mid Copeland and Allerdale.

c) SAFE ENOUGH - The public are being misled over escalating radiation risks by the use of ALARP (As Low As Reasonably Practicable), the Waste Hierarchy and Best Available Techniques to recycle, incinerate and dispose of radioactive wastes by increasingly novel routes from recycling radioactive scrap metal to burial of high level wastes in sub-sea geology.




Consultation: Part I UK policy proposals for managing radioactive substances and nuclear decommissioning


1. Do you agree with the proposal to require the application of a risk-informed approach as a decision-making framework for the management of all solid radioactive waste?


NO. The public are being misled into answering Yes to this question - who would disagree with a “risk informed approach?” But what the consultation fails to reveal (or even refer to as far as we can see) is that the industry uses a device called ALARP which was instigated following a court case in 1949. A coal mine employee had been killed by a rock fall that might have been prevented if the tunnel roof had been shored up by the operator the UK National Coal Board (NCB). The appeal court’s decision was that the NCB did not have to take every possible physical measure to eliminate risk; it only had to provide protection where it was required.


This judgement enabled business owners to defend themselves from successful legal action by showing that they had taken all “reasonably practicable” measures to ensure safe operation, and that therefore risks were “As Low As Reasonably Practicable” or ALARP.  The nuclear industry has taken this principle and used it to apply to radiation protection for the public - the consultation does not make any mention of ALARP but does mention its facilitator “Best Available Technique” which aims to provide “value for money” ie the cheapest option measured against human life.


If risk is either impossible or hugely expensive to reduce the industry chooses to do what is “reasonably practicable” to manage it and label the process “ALARP”.  The obvious alternative is that the process would have to shut down. The ALARP principle for fatality risk is effectively set at 1 in 10,000 per annum for members of the public and 1 in 1000 per annum for nuclear workplace risks. Even by this optimistic industry standard the public risk from radioactive emissions is twice that of a fatality by car accident (one in approx 20,000 according to some statistics) and in a reverse lottery many times greater than that of winning the National Lottery - the difference being that the public can choose to avoid the fatal traffic accident or winning lottery ticket. This equates to thousands of ALARP deaths every year due to radioactive emissions even by the industry’s own optimistic standard.


An example of this is the decommissioning of Sellafield’s Pile 1 and 2. A new landfill area called Calder Landfill Extension Segregated Area Disposals (CLESA) for nuclear waste dumping was created to dispose of wastes from the demolition. “This Best Available Techniques (BAT) justification demonstrates that the environmental permit for CLESA should be varied to allow it to accept radioactive waste material with higher levels of tritium..” Despite the Environment Agency previously pointing out in 2014 “ it is doubtful whether the location of the LLWR site (at nearby Drigg) would be chosen for a new facility for near-surface radioactive waste disposal if the choice were being made now. It would not be in accordance with current national and international siting practice for new facilities.” Despite knowing that radioactive wastes that will still be dangerous to the public in many decades to come will sooner or later end up scattered along the beach and in the sea the Environment Agency have acquiesced to Sellafield’s ‘necessity’ for a newly enlarged landfill just metres from the Irish Sea containing radioactive rubble using ALARP and BAT to justify the industry’s ‘need’. Coinciding with ALARP and BAT is the fact that in recent years the Environment Agency once fully autonomous from Government (and the nuclear industry) have been systematically declawed with massively reduced funding over recent years to become less of a watch dog than a lap dog.





Image the Calder Landfill is Expanding next to the Irish Sea in order to dump decommissioning wastes from Piles 1and 2 along with radioactively contaminated animal carcasses etc 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




2. Do you agree that application of the waste hierarchy should be an explicit policy requirement for the management of all solid radioactive waste where practicable?


NO. Radiation Free Lakeland have previously warned that the application of the “waste hierarchy” has opened up novel routes to the environment with increasing radioactive risks to the public. Examples:


LILLYHALL LANDFILL- prior to 2007 it did not recieve any nuclear waste apart from small amounts of Naturally Occuring Radioactive Wastes (NORM) from the oil industry - but reclassifying waste through the “waste hierarchy” has resulted in previously banned radioactive wastes being sent to landfill. Despite vigorous opposition to Lillyhall near Workington being used as a radioactive waste dump for nuclear sites including from Scotland, it was given the go ahead and in 2010 the inevitable happened in that Sellafield along with the newly allowed radioactive wastes “accidentally” sent four bags of illegal increased activity wastes including one bag of intermediate level waste. This was discovered and Sellafield fined - but the dumping continues.


RADIOACTIVE METAL RECYCLING

Application of the waste hierarchy has seen the opening of the Studsvik plant (now Cyclife) in Workington. Major employer, Iggesund packaging company was one of the local businesses vehemently opposed to Studsvik. Local councils both parish and borough strongly opposed the decision allowing the radioactive metal recycling site to go ahead.   In 2009 the newly formed Radiation Free Lakeland, urged the Nuclear Installations Inspectorate not to licence the site, arguing that it was irresponsible to recycle radioactive scrap metal onto the open market rather than for re-use in the nuclear industry and impossible to eliminate “hot spots” of radioactivity in the recycled metal. Concerns were ignored, since then there have been safety breaches.  The radioactive scrap metal plant has now been given permission to ‘store’ excess containers at the Port of Workington. Original plans for the Studsvik site in 2007 were for 15 containers, and this has now increased to 160 containers with the Port of Workington also now being used to “store” containers of radioactive scrap metal.



Image: overflowing containers of radioactively contaminated scrap metal at Lillyhall Industrial Estate - Cyclife (formerly Studsvik).



INCINERATION OF RADIOACTIVE WASTE
 Radioactive waste is through the “waste hierarchy” being increasingly sent for incineration. There are plans to open up a new radioactive waste incinerator at Preston’s Springfields site. The Westinghouse operators of Springfields (now called the “Clean Energy Technology Park”) have teamed up with another US company called Perma-Fix and the plan is to import European radioactive wastes from low to intermediate, to burn just a few miles from Preston City Centre. This is a direct result of the implementation of the “waste hierarchy” combined with ALARP and BAT and is an indication that the nuclear waste industry is increasingly out of control and with new build underway ever hotter nuclear wastes would arise.


3. Do you agree with the proposed amendment to current policies on geological disposal to allow disposal of Intermediate Level Waste in near surface facilities?


No. The NIREX inquiry of 1997 rejected the deep disposal of Intermediate Level Wastes. Nirex’s aim was “to prevent radioactive material from coming into contact with groundwater in which it could dissolve, because this is the principal route by which radioactive material could be transported from a repository through the overlying rock to



Map showing land newly acquired on a long lease -the NDA are in the process of buying up more land in the vicinity. Map also shows mine/mineral rights released (with delays and reluctance) to Drigg resident under Freedom of Information.



the surface where it could affect humans.” The Nirex inquiry concluded that this aim could not be achieved with deep disposal of ILW. Roll on 20 years and this fact is airbrushed out with the plan for Near Surface Disposal which would mean that Intermediate Level radioactive wastes would reach groundwater and the surface far sooner than the rejected NIREX plan for deep disposal.  In a dangerous mission creep, 16  boreholes 120 metres deep have already been drilled at the Low Level Waste Repository to look at the possibility of Near Surface Disposal of Intermediate Level Wastes.    The Near Surface Disposal Plan for Intermediate Level wastes is also being looked at in order to “co-locate” with the Geological Disposal plan for High Level wastes.  Near Surface Disposal would be delivered far faster – within 10 years and would provide a ‘gateway’ to the GDF with shared access from surface facilities. At one of the “Community Partnership” events in the village of Drigg when I asked about the co-location of Near Surface and Geological Disposal I was told that “Near Surface Disposal of Intermediate Level Wastes has nothing to do with us!”


DRIGG

Meanwhile “The Nuclear Decommissioning Authority has asked LLWR (at the village of Drigg) to conduct a feasibility study to assess the capacity of the LLWR site as part of their wider studies on near-surface disposal. This assessment is being delivered as part of the LLWR Environmental
Safety Case (ESC) review. It includes the drilling of new characterisation
and monitoring boreholes that reach a maximum depth of 120 metres. All of which are within the LLWR site boundary. It is important to note that development of a near-surface disposal facility for some ILW, whether at the LLWR site or elsewhere in England,
would require an amendment to Government policy..” https://www.whatdotheyknow.com/cy/request/are_the_16_rock_characterisation?unfold=1

The public have not had a say on this plan in any way.


VOICELESS

The public have also had no say on other “investigative techniques” for GDF which have taken place ahead of any supposed “test of public support”. A highly contentious case resulting in a petition of almost 55,000 is the seismic blasting carried on under instruction from Nuclear Waste Services who in turn are being advised on “investigation techniques, costings and construction” by the Committee on Radioactive Waste Management.


It is of huge concern that the key advisor for CoRWM is the CEO of West Cumbria Mining Ever since the appointment of Mark Kirkbride to the Committee on Radioactive Waste Management in 2019 immediately following the County Council’s first approval of his coal mine, we have argued that there is a deep conflict of interest at the heart of government on this issue. Government on the one hand have the final say on Mark Kirkbride’s coal mine business interests which includes through the Coal Authority (under BEIS/now Department for Energy Security and Net Zero ie the authors of this consultation) renewing a conditional licence to drill and on the other hand are employing Mr Kirkbride to provide costings and “invaluable” advice on the burial of nuclear wastes. The expedient application of Best Available Technique and safety risks As Low as Reasonably Practicable has everything to do with Near Surface Disposal of Intermediate Level Wastes and the “co-location” with a sub-sea GDF for High Level Wastes.

The public have been denied sight of the full costings provided to CoRWM and NWS by







Images: Wastwater Chronicles


Mark Kirkbride despite repeated FOI requests. Mark Kirkbride has, say CoRWM, provided fuller costings unofficially to a PHD student (in 2020). We note that the suppliers advised by Mark Kirkbride are the same as the “preferred suppliers” for his coal mine which lies between two areas in the frame for GDF, Mid Copeland and Allerdale.



4. Do you agree with the proposed policy framework for the development of near surface disposal facilities by the NDA for the disposal of less hazardous ILW?


No. See answer above. “less hazardous” does not mean safe to “dispose” by shallow grave.



5. Do you agree that the policy of the UK Government and devolved administrations should promote the use of on-site disposal of radioactively contaminated waste from the decommissioning of nuclear sites, subject to environmental permits?


No. See 3. and 4. Waste cannot be “disposed” unless radioactivity has reduced to background levels. Radioactive waste should be retrievable, monitorable and able to be repackaged/shielded giving future generations the ability to protect themselves


6. Are there any further improvements that we might consider in relation to the proposed update of the nuclear decommissioning and clean-up policy?

Yes - see 3. 4. And 5. In addition the first step is to stop the process of generating more nuclear wastes.


7. Do you agree with our proposed updates to the policy statement on the management of spent fuel?

No. See 6. Reprocessing spent fuel should be banned completely. Reprocessing generates ever more waste streams to be discharged to the environment and increases the volume of nuclear wastes dangerous to all life forms by at least 160 times. Sellafield’s reprocessing wastes are found in the Arctic but much of the waste has settled on the Irish Sea bed to be resuspended with the tides and activities such as borehole drilling and subsidence from sub-sea mining.


8. Do you agree with our proposed policy statement on the management of uranium?

No. Uranium should not be ‘re-used.’ Uses of uranium include military use which should be banned as it is effectively a chemical weapon. Depleted uranium is used for tank armour, armour, armour piercing bullets and aircraft weights. Depleted uranium is both a toxic chemical and radiation health hazard when inside the body.



Consultation: Part II Draft UK policy framework for managing radioactive substances and nuclear decommissioning


1. Do you think that the draft policy statements on radioactive sources accurately reflects existing practice and regulation?


No - For example — “Programme Cyclamen - a joint initiative between UK Border Force and the Home Office, that aims to detect and deter the illicit importation of radioactive or nuclear materials as part of CONTEST – can also incidentally detect orphan sources at transport terminals, which are occasionally found in scrap or contaminated items.” This is meaningless while the industry choose to implement BAT, ALARP and the Waste Hierarchy which results in dispersal of radioactive materials routinely and inadvertently to the public realm. Stopping the “Illicit importation of radioactive materials” is the right thing to do - but how then does the industry justify the planned import of Intermediate Level radioactive wastes from Europe to be incinerated at Preston? “Plans to jointly develop a state-of-the-art advanced materials treatment facility in the UK have been announced by Westinghouse Electric Company and Perma-Fix Environmental Services. To be built at Westinghouse's Springfields site, the facility will expand waste treatment capabilities for the European nuclear market” from World Nuclear News March 2022.



2. Do you have any suggestions on how to improve this chapter on radioactive sources?


Yes - The regulators should be fully autonomous, independent of government and fully funded. The industry should not be left to self-regulate, monitoring should be done independently of industry.


Radiation risk to the public realm should not be measured by ALARP or facilitated by BAT and the Waste Hierarchy which inevitably leads to novel routes of disposal and increased radiation exposure. RADMIL should be reinstated in areas where the nuclear industry operates:


From: ENV Lancashire County Scientific Services
scientificservices@lancashire.gov.uk
Date: 31 March 2014 14:44:29 BST
To: ‘marianne Birkby’

Subject: RE: RADMIL

Dear Ms Birkby

The decision to discontinue radiation monitoring was taken about three years ago
by the Lancashire Chief Environmental Health Officers group. This was mainly due to budgetary pressure and the recognition that the background levels of radiation were very well established.

It was also decided that the remaining equipment would be held by Lancashire
County Scientific Services and maintained in good working order in case it might
assist in the recovery phase of an nuclear incident.

As the pressures on budgets have not eased I cannot see RADMIL being reinstated in the foreseeable future.

I hope this answers your question adequately. If you need any further information please do not hesitate to contact me.

Regards

Andrew Smith, BSc., PhD., M.Chem.A., C.Sci., C.Chem., M.R.S.C.

Lancashire County Council
County Scientific Services


3. Do you think that the draft policy statement on radioactive liquid and discharges accurately reflects existing policy, practice and regulation?

No - see 1 and 2


4. Do you have any suggestions on how to improve this chapter on radioactive liquid and gaseous discharges?

Yes - see 1 and 2


5. The solid radioactive waste policy set out above includes existing policies that would be implemented if the proposals in Part 1 are taken forward. Do you agree that the policy statement captures all relevant policy on managing solid radioactive waste?

No - see our replies to Part 1 re NIREX etc In addition the CEO of West Cumbria Mining is key advisor on NSD and GDF plans - this cronyism and conflict of interest renders the proposals void.


6. Do you have any suggestions for how this chapter on managing solid radioactive wastes could be improved?

Yes - see our replies to Part 1 re NIREX etc also the appointment of the CEO of West Cumbria Mining as key advisor renders the policy void.


7 -12 FORGET IN SHALLOW OR DEEP GRAVE? OR LOOK, SEE, DO SOMETHING?

Nuclear waste should not be “disposed” of in either shallow or deep graves where it will percolate to the surface. Future generations should have the option of retrieval, repacking and shielding themselves from radioactive emissions. The first step is to cease generation of radioactive wastes rather than to increase the “allowed” dose and search novel ways to most expediently “dispose” of wastes via ALARP, BAT and the Waste Hierarchy.

“Animal studies provide evidence of persistent transgenerational effects, possibly involving genomic instability after the initial radiation dose from Chernobyl fallout. Saturation dose effects were observed, even at low levels of radiation exposure. If the animal model is applied to human populations, this suggests that genetic effects may persist for more than 600 years after initial radiation exposure of the first generation. The existing radiobiology paradigm, which is fundamental to the estimation of environmental radiation risk, cannot explain the phenomena of radiation-induced genomic instability and the bystander effect. Current radiation protection standards for genetic risk appear to be optimistic. This has important implications for the use of nuclear power.” Why the Nuclear Industry is Killing Off the Human Race by John Urquhart https://mariannewildart.wordpress.com/2016/11/14/guest-blog-why-the-nuclear-industry-is-killing-off-the-human-race-by-john-urquhart/


In Conclusion:

RaFL do not recognise the validity of this consultation for the following reasons:


a) TIMING - It is taking place at a time when the most expedient ( proximity to Sellafield ) target area for nuclear waste disposal is undergoing the upheaval of Local Government Organisation.

b) CRONYISM - The NDA and Nuclear Waste Services are being advised on “Investigation Techniques,” “Construction” and “Costings for Scenarios” including “co-location” of a GDF and NSD by the CEO of West Cumbria Mining. Mark Kirkbride’s coal mine, now approved by Government, lies directly between the target areas of Mid Copeland and Allerdale.

c) SAFE ENOUGH - The public are being misled over escalating radiation risks by the use of ALARP (As Low As Reasonably Practicable), the Waste Hierarchy and Best Available Techniques to recycle, incinerate and dispose of radioactive wastes by increasingly novel routes from recycling radioactive scrap metal to burial of very hot high level wastes in sub-sea geology.


References:





Drigg Radioactive Landfill Environment Agency - erosion and dispersal of radioactive wastes




An assessment of the radiological capacity has shown that there is scope to safely increase the disposal limits. A number of options have been proposed, all of which involve moving to an average activity limit of 200 Bq/g per consignment (a single vehicle load), for disposals to the main body of the site. A higher maximum activity limit is proposed for hotspots within a consignment or surface contaminated decommissioning wastes within a consignment (40,000 Bq/g beta and 1,700 Bq/g alpha). This means that the site could safety receive decommissioning wastes where the volume average activity is up to 200 Bq/g, but the peak CLESA PCRSA Review Report December 2017 Page iv activity is above 200 Bq/g because it is confined to the surface of the waste item (e.g. concrete block).



Waste Hierarchy/Novel Routes/Lillyhall - Letter from DECC to Radiation Free Lakeland https://mariannewildart.files.wordpress.com/2014/02/letter-from-decc-lillyhall-radioactive-waste-dump.jpg














Mark Kirkbride’s “unofficial” advice to PHD student on costings for GDF https://pure.manchester.ac.uk/ws/portalfiles/portal/182559187/FULL_TEXT.PDF










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