A report corrects #Sellafield #nuclear damage to #Ireland scenario from the #UK. #ESPOO #BREXIT

…Prof Chris Busby first consulted the online NOAA Hy-Split atmospheric projection software with the same date as the EPA report and got a completely different scenario showing most of Ireland being covered with meandering waves of highly radioactive particles and gases….

REPOST due to images being hacked from page

Introduction by Shaun McGee (aka arclight2011)

Published exclusive to nuclear-news.net (Creative Commons applies)

2 February 2018

The Irish Sellafield nuclear accident fallout projection report has some issues, in my opinion.
In December 2016 the Irish Environmental Protection Agency (EPA) published in Irish Media Sources a report on radioactive fallout from a “worse case” scenario.

At the time, I was in contact with the Irish EPA concerning new evidence that shows a larger health effect from radiation sources and I was trying to challenge the pro nuclear bias that underestimated the health and environmental problems using mechanisms from the EURATOM nuclear treaty in Europe. I have to say that the Irish EPA were forthcoming in their many responses to my inquiries but eventually we reached a stale mate as the EPA claimed that the specific Isotopes relevant to the Euratom Treaty are not to be found in Ireland with the exception of Iodine 131 which they claimed was unlikely to be a health problem. They said that other fission (from a nuclear reactor) isotopes were not found on the island of Ireland.
The 2016 report from the Irish EPA (link) shows, what I think, is a minimal dispersion of radioactive fallout with little impact to health or the environment. However, there are other reports of fallout plumes from the Sellafield site that show much worse contamination than the 2016 EPA report posits and I requested Prof Chris Busby (who had been involved with Irish activists and government groups concerning Sellafield) to do a report (Full report below) on the problems that seemed to be highlighted with the Irish EPA report.
Prof Chris Busby first consulted the online NOAA Hy-Split atmospheric projection software with the same date as the EPA report and got a completely different scenario showing most of Ireland being covered with meandering waves of highly radioactive particles and gases. He then consulted 2 other reports, one of which the Irish Government commissioned that was completed by 2014 using the European gold standard software fallout projection model that showed a large plume covering large sways of Ireland (reaching the south west coast).
It would seem that the 2016 report completely runs counter to the 2014 and earlier report as well as the Hy-Split projection whilst using the same date as the 2016 Irish report.
So the issue of the types of accident that the Irish EPA thought to be worse case scenario. A direct hit by a Meteorite was seen to be plausible but if a meteorite hit sellafield then much of the nuclear site would be lofted high into the atmosphere and more evenly spread around the globe. This would fudge the numbers for plumes that are moving nearer the ground.
No where in the report was the more likely and and more dangerous scenario of terrorists attacking the spent fuel pools causing low altitude fallout over many weeks that would cause a larger pollution incident that would effect local countries to the UK border such as Ireland, Norway etc.In fact such concerns have been reported in main stream media sources as well as government/private think tanks.

Thanks to Prof Chris Busby for taking the time off his busy schedule to compile a response to the Irish EPA report on Sellafields projected damage to Ireland.

Please feel free to leave a comment belowif you agree or disagree with any of the points raised, a discussion about this issue needs to be had.

Shaun McGee (aka arclight2011)

………………………………………………………………………………..

Conclusion to report

The EPA 2016 report is unsafe and cannot be relied upon by the public, the media or administrators. The anonymous authors have shown extraordinary bias in every aspect of the report. They made elementary mistakes in their source term listing of isotopes, by including those which had short half-lives and will clearly not have been present in any significant concentration. They omitted a whole series of nuclides which are present in the tanks and the fuel pools. They choose a source term which is demonstrably too low based on available data, they choose a worst-case accident which involves only one HAST tank and only Caesium-137. They omit mentioning the spent fuel pools which are a highly likely site of a major coolant loss and subsequent fire or explosion. Their air modelling results are extremely unusual with implausibly narrow plumes, whilst a NOAA HYSPLIT model for the same day shows a completely different dispersion covering most of highly populated Ireland. Their surface contamination levels are 200 times lower than a previous computer model by Dr Taylor, which they must have had access to, and they fail to calculate the increased levels of cancer in the exposed population. This has been rectified here.

Historic releases from Sellafield to the Irish Sea have caused measurable increases in cancer and leukemia in coastal populations of Ireland. There is no doubt that the existence of Sellafield represents a potential catastrophic danger to the Irish Republic. A serious accident there could destroy the country and also most of Britain. As the Chernobyl accident effects showed, and the Fukushima accident effects will reveal (and in the case of Thyroid cancer have revealed) the ICRP risk model is unsafe for explaining or predicting health effects from such contamination. The Authors of the EPA 2016 report should be sanctioned in some way for producing such a travesty of the real picture, especially since they will have had access to the earlier study and modelling by Peter Taylor and the details of the COSYMA model employed by him.

Christopher Busby

August 17^th 2017

Using recognised plume projection software for same day

UK version given to Irish EPA for same day

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The health impact on Ireland of a severe accident at Sellafield.

A criticism of the report “Potential radiological impact on Ireland of postulated severe accidents at Sellafield” Anon. (Radiological Protection Institute of Ireland: September 2016) with a re-assessment of the range of health outcomes.

Christopher Busby PhD

There are things we know that we know. There are known unknowns. That is to say there are things that we now know we don’t know. But there are also unknown unknowns. There are things we do not know we don’t know.

Donald Rumsfeld

Murphy’s Law is an adage or epigram that is typically stated as:

Anything that can go wrong will go wrong.

[https://en.wikipedia.org/wiki/Murphy%27s_law]

Introduction

The nuclear complex at Sellafield in Cumbria, UK, has always represented a real danger to the Republic of Ireland. There has been and remains a chronic danger to the people of the East Coast of Ireland. First, radioactivity released from Sellafield under licence to the Irish Sea, particularly in the 1970s did not, as had been hoped, dilute and disperse in the sea, but instead became attached to sediment particles along the coasts and inlets of Ireland (e.g. Carlingford Lough, Drogheda) and the particles represented a cause of cancer and illnesses in coastal populations and those exposed through eating fish and shellfish. A court case (Herr and Ors. Vs BNFL) was supported by the Irish State and my organisation was funded by the Irish State for 3 years from 1998 to examine the contamination and health issue. Green Audit examined the cancer rates in small areas in North and mid Wales, and also in Ireland by distance from the contaminated coasts. Results were published in Busby 2006 and showed that there had been a significant 30% increase in cancer and leukemia in coastal populations of the Irish Sea [1]. The second issue of continuing interest is the danger of a serious accident at Sellafield at a time when the wind direction is from the East and airborne material passes across Ireland. This issue became more urgent and of interest to the Irish public after the Fukushima Daiichi reactor explosions and melt-downs in Japan in 2011. However, the potential outcome of such an accident had been part of a report by Peter Taylor [2] written in 1999 for McGuill and Company, the solicitors representing the Herr and Ors vs. BNFL case which was abandoned by the Irish State for reasons which remain unclear.

In September 2016, a report was produced by the EPA Office of Radiological Protection entitled Potential radiological impact on Ireland of postulated severe accidents at Sellafield. [3]. This anonymous report has serious shortcomings and errors which will be addressed here. A more realistic assessment of the potential impact of a serious accident at Sellafield on the Republic of Ireland will be presented here using the radiological risk models both of the International Commission on Radiological Protection (ICRP, [4]) and also the Model of the European Committee on Radiation Risk (ECRR [5]).

 

2. The baseline assumptions of maximum release.

2.1 The EPA worst case.

The EPA report discussed some possible accidents involving releases of radionuclides. It examined some potential sources of radionuclides but not others. It chose a number of possible scenarios, but excluded others. In general terms (and referring to Murphy’s Law, appropriately in this case of Ireland) it could not assess accidents which are totally unforeseen. Therefore, also in general, we should consider a worst case-scenario in which most of the radioactivity inventory of the Sellafield site becomes airborne at a time when the weather patterns were most unfavourable for Ireland.

For example, in Busby 2007 [1] the Windscale reactor fire was examined in some detail. At the time of the fire, which continued for some days, the main releases were initially offshore towards Ireland. This is contrary to the discourse promoted by the British Radiological Protection Board in 1974. It is, however confirmed by Air Ministry historical data. But the point is that at the time a cold front laying North East to South West was moving from Ireland towards England across the Irish Sea. This meant the releases from the fire and heavy radioactive rain fell along the front. This rain fell on the Isle of Man, and historical mortality data show a large increase in the death rate after this event. There have also been reports of significant birth effects (Downs Syndrome cluster) in County Louth reported by the Irish GP Patricia Sheehan, who died in an automobile accident shortly after beginning to follow this up.

In order to estimate the effects of a worst case, initially there must be a choice of the source term, that is, the quantity and radionuclide identity of the material released to the atmosphere.

The EPA report decided that this could be modelled as the contents of one of the 21 High Active Storage Tanks (HAST). The true content of one of these is unknown, probably also to the operators BNFL. The estimate for the contents was taken from a report by Turvey and Hone [6]. This is shown in Table 1 below where I note a number of concerns. In Table 2 I provide examples of some hazardous radionuclides not listed in the EPA source term table. In Table 3 I copy the source terms used by the British 1976 Royal Commission (the Flowers Report) [7]. Note that all these estimates are for a single or multiple HAST tanks on the tank farm and exclude explosions of the spent fuel ponds which could dry up and suffer prompt criticality. This could result from a domino scenario (see below).

Table 1 EPA assumed release source term. (E-notation, thus 1 x 10¹⁴ is written 1 E+14_

Radio nuclide	Total activity Bq	Half Life	Comment
Zr-95	1.4 E+15	64days	All decayed away; almost none there
Nb-95	5.8 E+14	35 days	Daughter of Zr-95; all decayed away; none there
Ru-106	1.33 E+16	366 days	All decayed away; almost none there
Sb-125	1.6 E+15	2.7 years	All decayed away; almost none there
Cs-134	1.04 E+16	2.0 years	All decayed away; almost none there
Cs-137	5.26 E+17	30 years	Significant
Ce-144	9.65 E+15	284 days	All decayed away; almost none there
Eu-154	4.41 E+15	8.5years	Minor significance now
Eu-155	3.39 E+15	5 years	Minor significance now
Sr-90	3.6 E+17	28.8 years	Highly Significant; DNA seeker
Am-241	2.72 E+15	432 years	Highly Significant alpha; decays to Np-237 alpha; daughter of Plutonium-241
Cm-242	4.57 E+13	162 days	All decayed away; almost none there
Cm-243	1.92 E+14	32 years	Highly Significant alpha; decays to Plutonium-239, so there must be approximately the same or more Plutonium-239 (fissionable) in the mix

2.2 Concerns about the source term table of the EPA 2016 report

Table 1 gives the source terms employed by the EPA report. It lists 13 isotopes. The table is an astonishing example of bad science, produced either through bias or ignorance. Since the table is apparently taken from another report by Turvey and Hone 2000, we can perhaps blame them for the original mistakes. I have included a column showing the half-lives of their isotopes. The main concerns are as follows:

It is perfectly clear than all but four of the thirteen will have physically decayed away by 2016. For example, a half life of Zr-95 of 65 days, at 1980 would by now have had 36 x 365 days to decay. This is 202 half-lives. There would be virtually none left of the listed quantity.
A significant number of seriously hazardous radionuclides which must be in the tanks are not listed. In particular we have Plutonium-239, Plutonium- 238, Plutonium-241, Uranium and other actinide alpha emitters including Neptunium-237, Radium-226, Carbon-14 and Tritium.
The overall total activity tabulated the EPA report is about 4 times less than the quantity in a HAST tank given in the report of the UK Royal Commission 1976 (Flowers) and the 1977 Windscale Enquiry which totalled 1.8 x 1018 Becquerels of Caesium-137 plus 1.4 x 1018 Bq of Strontium-90 plus 1.1 x 1018 Bq of Ruthenium-106 [8].
Why did the EPA report reduce the quantities assumed by the earlier reports? Why did it omit the dangerous actinides Uranium, Plutonium and Neptunium with the exception of Americium-241? Why did it omit a whole range of other radionuclides like Tritium and Carbon-14?

Table 2 Some Missing isotopes from the EPA Source term with longer half-lives or present as daughters

Isotope	Half Life
U-238	4.5 E+9y	Alpha
U-235	7.1 E+8y	Alpha
U-234	2.4 E+5y	Alpha
Th-230	8 E+4y	Alpha
Ra-226	1599y	Alpha
Pu-238	86.4y	Alpha
Pu-239	2.4 E+4y	Alpha
Pu-241	14.4y	Decays to Am-241 listed by EPA
Np-237	2.1 E+6y	Am-241 daughter
Mn-54	312d	Activation
Co-60	5.27y	Activation
Y-90	64h	In equilibrium with Sr-90
H-3	12.3y	Life component; radioactive water
C-14	5730y	Life component

Table 3 HAST tank content according to Windscale Enquiry 1977 and Royal Commission 1976

Isotope
Quantity(Bq)
Cs-137
1.8 E+18
Sr-90 + Y-90
2.8 E+18
Ru-106
1.1 E+18

2.3 The more accurate source terms for HAST tanks

Taylor 1999 [2] based his calculations on only Cs-137 and assumed a source term of 1 x 1018 Bq. Therefore, his results (which I will review below) should be adjusted by a factor of 1.8 on the basis of the Table 3 results, but particularly also modified upwards by the presence of the Sr-90/Y-90 and the actinides, the Plutonium, Uranium, Radium and Americium, which, though they are present in smaller quantities each carry a weighting of 20 due to their alpha biological effectiveness. Thus the quantity of 2.72 E+15 listed by EPA in Table 1 has the effect (in Sieverts) of 5.44 E+16 due to its alpha emission.

2.4 The spent fuel pools

In addition to HAST tank scenarios, there has been reported the existence [ 9: http://www.theecologist.org/News/news_analysis/2611216/leaked_sellafield_photos_reveal_massive_radioactive_release_threat.html%5D in a very dangerous state, a series of concrete spent fuel pools containing hundreds of tons of spent fuel. Loss of integrity of these tanks (drying up) would result in meltdown and prompt criticality with explosive distribution and burning of the spent fuel elements.

The approximate activity inventory of a spent fuel assembly for a Boiling Water Reactor is available from Alvarez 2014 [10] and the EIA for a Pressurized Water reactor fuel assembly from the Swedish Forsmark High Level Waste repository documents [11]. Therefore these are not exactly the same as the assemblies in the Sellafield pools. However, they will not be very different. The radioactive elements and their activity is given in Table 5 [Ref 5,6] .

Table 5 Approximate activity of an estimated 800 spent fuel assemblies in the Sellafield

			per assy	per 1000
nuclide	halflife	curies	Bq	Bq
Am242m	150y	2.88	1.0656E+11	1.0656E+14
Am241	430y	373	1.3801E+13	1.3801E+16
Am243	7400y	8.63	3.1931E+11	3.1931E+14
Cs134	2.1y	1310	4.847E+13	4.847E+16
Cs137	30y	24100	8.917E+14	8.917E+17
C14	5700y	0.21	7770000000	7.77E+12
Cd113m	14y	22700	8.399E+14	8.399E+17
Ce144	284d	17.3	6.401E+11	6.401E+14
Cm243	29y	5.55	2.0535E+11	2.0535E+14
Cm244	18y	923	3.4151E+13	3.4151E+16
Cm245	8500y	923	3.4151E+13	3.4151E+16
Cm246	4700y	0.04	1480000000	1.48E+12
Eu154	8.8y	192	7.104E+12	7.104E+15
H3	12.3y	105	3.885E+12	3.885E+15
Kr85	11y	1170	4.329E+13	4.329E+16
Np239	400d	8.63	3.1931E+11	3.1931E+14
Pm147	2.62y	2110	7.807E+13	7.807E+16
Pu238	88y	1020	3.774E+13	3.774E+16
Pu239	24000y	54.1	2.0017E+12	2.0017E+15
Pu241	14y	15700	5.809E+14	5.809E+17
Ru106	376d	90	3.33E+12	3.33E+15
Sb125	2.77y	120	4.44E+12	4.44E+15
Sm151	90y	67	2.479E+12	2.479E+15
Sr90	29.1y	16600	6.142E+14	6.142E+17
U238	4.4Bny	0.06	2220000000	2.22E+12
U236	23My	0.07	2590000000	2.59E+12
U234	244000y	0.24	8880000000	8.88E+12
U232	72y	0.01	370000000	3.7E+11
Y90	64h	16600	6.142E+14	6.142E+17
Zr93	1530000	0.35	1.295E+10	1.295E+13
		104201	3.8554E+15	3.8554E+18

Comparisons with releases from Chernobyl and Fukushima

Since all these numbers are meaningless without comparisons, Table 6 gives comparisons in terms of Cs-137, which has become a yardstick for releases, discharges and ground contamination in the last 50 years with three contamination events, Chernobyl, Fukushima and the 1950-1980 atmospheric nuclear tests. These are useful comparisons since in the cases of Chernobyl and the nuclear tests, we have evidence for the effects on human health, an issue which is discussed later.

Table 6. Contents of one HAST tank, the spent fuel pools at Sellafield with releases from Chernobyl, Fukushima and Atmospheric bomb tests.

Event/ contents
Cs-137 (Bq)
Reference
Atmospheric Nuclear weapons tests (Global)
5000 E+15
UNSCEAR 2000
Chernobyl
38 E+15
UNSCEAR, Busby 2013
Fukushima initial
37 E+15
Various, see Busby 2013
Fukushima contents
3000 E+15
Various, see Busby 2013
One Sellafield HAST Tank
1850 E+15
1977 Windscale Enquiry. 1976 Royal Commission (Flowers).
Sellafield Spent Fuel Pools
1000 E+15
Estimate based on photograph and Alvarez 2014
21 HAST Tanks
38850 E+15

Total Sellafield
40000E+15

Ireland EPA Source term
526 E+15
EPA 2016

A domino scenario

There are 21 HAST tanks which, from the 1976 Royal Commission report [2] and the 1977 Windscale enquiry [3] can be assumed to contain 50 Million Curies (1.8 x 1018 ) Becquerels of Caesium-137 plus 40 Million Curies (1.4 x 1018 Bq) of Strontium-90 plus 30 Million Curies of Ruthenium-106 (1.1 x 1018 Bq). In addition there are, of course plenty of otheradionuclides which can be added in (See Table 2). All initial scenarios involve an explosion of a single HAST tank. This would undoubtedly result in high level contamination of the whole Sellafield site, such that access of human personnel would be restricted because of the lethal radiation fields. This would affect the ability of personnel to maintain the security of the cooling systems for the other HAST tanks and the spent fuel pools. In the case of Fukushima, access to the damaged reactors and the areas surrounding them was impossible due to the lethal radiation levels. This domino effect is quite possible, having been the cause of the sequential explosions at Fukushima as one reactor after another lost cooling and melted down.

Modelling unlikely scenarios; the worst case source term

It should be noted that Uranium and Plutonium, together with other alpha emitters are not assumed to be present in the EPA source term which focuses exclusively on Cs-137. However, more than 98% of the mass of material in the spent fuel pools consists of Uranium and Plutonium, and loss of coolant there can result in prompt criticality following melt down and a Zirconium Magnesium fire. Thus a nuclear explosion as well as a radiolytic hydrogen explosion is a possibility. Since the EPA report was advertised as a worst case scenario, given Murphy’s Law, and Rumsfeld’s warning, such events should have been modelled, however the analysis shows them to have been vanishingly unlikely.

3. The baseline assumptions of exposure

3.1 The EPA dispersion model and assumptions

The EPA have employed an atmospheric dispersion model named RIMPUFF which I do not have access to. Their report chooses a specific day, 29th Nov 2010 when the wind was apparently Easterly and carried the dispersed radioactivity across Ireland. Their map of the air concentration dispersion is of interest and I copy it in Fig 1 below.

Fig 1 The EPA air modelling result for Nov 29th 2010. Caesium-137 in air (isolines 1 x 106 Bq.s/m3 and 1×107 Bq.s/m3 (hatched))

(b) Caesium-137 Surface deposition (wet) (isoline 1 x 105 Bq/m2)

The interesting feature of this model is that it shows an unrealistically narrow dispersion for the plume. In order to examine this issue further I ran the air modelling computer program of the US National Oceanographic and Aeronautic Agency NOAA HYSPLIT [12] for a number of releases from Sellafield on the same day as the EPA RIMPUFF result. NOAA HYSPLIT employs meteorological data from a number of sources and is generally accepted to be a gold-standard dispersion modelling program. None of the results I obtained were close to the results shown by the EPA report. In particular, my concern is that the very large population of Dublin is entirely spared in the EPA model, whereas in all the NOAA HYSPLIT air models I ran for that same day, Dublin was directly in the path of the release plume. I show a series of developing particle dispersion maps calculated by the HYSPLIT model for unit release at 10am on 29^th November 2010 below in Fig 2. It is perfectly clear that the real plume will cross Dublin and contaminate most of Ireland.

Fig 2 (a) to (e) Sequential snapshots of position of particle plume from 24 h release beginning at 10am on 29^th Nov 2010 as calculated by NOAA HYSPLIT.

1. At 1400

2. 12 hrs later

3. 15 hrs later

1. 23 hours later

(e)Time of arrival of radioactivity

I have run several HYSPLIT model simulations with both short and longer releases. None of them give anything like the narrow plume presented by the EPA report and shown in Fig 1. It is certainly possible, given time and resources to make a comprehensive study of this issue, but for the purposes of this report it is sufficient to demonstrate that there are circumstances where the whole of the Republic of Ireland will be contaminated, and that the model employed by EPA 2016 is highly questionable.

3.2 Peter Taylor 1999

Between 1998 and 2001 Green Audit was commissioned to examine the health effects of the releases from Sellafield to the Irish Sea. At the same time, and in connection with the same case Herr and Ors vs. BNFL, Peter Taylor, a British Scientist working with the Oxford Environmental Group, which also included Gordon Thompson, made a study of the worst case scenario for a Sellafield accident and contamination of the Republic of Ireland. Taylor obtained a computer model COSYMA from the European Union and modelled a release only of Caesium 137, using 1 x 10¹⁸ Bq as a source term. Tables 3 to 6 suggest that this is conservative. The report was never published but was certainly shown to the Irish State, since the work was supported by it. It should therefore have been available to those creating the 2016 EPA report. Taylors Report [ref: A Major Accident Potential at Sellafield—The impact on Ireland, 48pp] was given to me by Dr Taylor. Taylor made several computer runs for different wind directions and Pasquil categories (a measure of turbulence) producing contamination maps and predictions of precipitation.. The program divides the release point into a number of sectors. For North Easterly airflow, and Pasquil category 1A Taylor’s results are shown in Fig 3 below. The level of contamination over the whole of southern Ireland including Dublin is predicted to be about 1 x 10⁷ Bq./m² . Taylor argues that the high levels of peat in Ireland will result in this Cs-137 remaining on the ground for a very long time. However, what we see here is a level of contamination of 10MBq/m² for a source term of 1 x 10¹⁸ Bq.

Fig 3. (a) Contamination map generated for easterly airflow by Taylor 1999 using COSYMA program. Blue line represents boundary of contamination. (b) area contamination by distance from source.

(3b) Contamination levels by distance from Sellafield (km)

3. 3 Cs-137 contamination: comparing Taylor and EPA 2016

The EPA assume a Cs-137 source term which is roughly half that of Taylor, but the surface contamination levels are significantly less. Taylor’s result is for surface contamination. The EPA result is for air concentration in Bq/m³. Additionally we see the EPA RIMPUFF plume is unnaturally narrow and also that assuming rainout the EPA calculate a very small area of contamination with only 1 x 10⁵ Bq/m², 10-100 times lower than the Taylor program found for most of Ireland.

3.4 The worst cases.

We already see that the HAST tank contents according to the 1976 Royal Commission is about twice that employed by Taylor. Both Taylor and EPA ignore the Spent Fuel pools. Taylor only models Cs-137, and in terms of contamination, this is also the case with EPA 2016. If we take the calculation by Taylor, together with the NOAA model, it is clear that most of Ireland will be contaminated to levels of Cs-137 contamination of the order of 10⁶ to 10⁷ Bq/m² . This is certainly case for the East coast and the highly populated coastal region including Drogheda and Dublin. Caesium-137 has become the yardstick by which such accidental contamination is presented. This is partly because the nuclide is very easy to detect as it has a strong and identifiable gamma peak at about 660keV. However, it is very likely that for internal exposures, the Strontium-90, and the alpha emitters are the most hazardous (see below). This is particularly so since the contamination is almost always in the form of micron and sub-micron diameter particles of Uranium, the main component by mass of nuclear waste. The Cs-137 and other radionuclides represent less than 5% by mass, and transport away from accidents involves the aerosolization of Cs-137 and other isotope contaminated particulates. But since it is the Cs-137 dose that is used as a yardstick for effect, we can stay with that and relate the subsequent health effects to the doses calculated on the basis of the Cs-137 contamination since this is most easily measurable. We have to at the same time admit that the internal exposure effects are not mainly form the Cs-137, but from the alpha emitters, nano- and micron particles.

4. Health effects

I will make two calculations of health effects, with end points being cancer and heritable damage as shown by congenital illnesses and infant mortality. Radiation exposure causes increased rates of all illnesses. On the basis of the effects found after Chernobyl in Belarus and discussed by Bandashevsky 2009 [13] we should expect a sudden increase in the death rate and also at the same time a sudden decrease in the birth rate following the contamination. I will do this using the ICRP risk model on the one hand and the risk model of the European Committee on Radiation Risk on the other.

4.1 Using the EPA 2016 approach for contamination and dose.

EPA 2016 calculate between 2 and 10mSv cumulative doses depending on whether the accident occurred in May or November based on a 5 x 10¹⁷ Bq source term. This is presumably to an adult living in the area that EPA model as being contaminated. EPA would not recommend evacuating anyone from the areas of peak contamination since it holds that 100mSv in one week is the correct evacuation criterion. This would presumably be based largely on the external groundshine. However the gamma dose rate from a contamination by Caesium-137 is about 1uSv/h per 300kBq/m² (FGR12 Part 2 [14]). At 1 x 10⁵ Bq/m² (100kBq/m²) shown in the small area that the EPA believe could be contaminated (Fig1) the dose rate would be 0.33uSv/h and a week’s dose would be about 50uSv. The EPA have not done so, but I will calculate the absolute cancer yield in a population of 1Million persons exposed to the doses calculated by the EPA of between 3 and 10 mSv using the methodology of the ICRP and that of the ECRR in Table 7.

Table 7 Absolute Cancer Yield in 1 million persons exposed to the EPA calculated contamination levels and doses using the ECRR and ICRP absolute cancer risk coefficients.

EPA 2016 1-y Dose	ICRP yield	ECRR yield
3000uSv	150	45,000
10000uSv	500	150,000

4.2 Using Taylors 1999 calculations for the doses.

Taylor 1999 did not numerically calculate doses or cancer effects for Ireland though he did for the whole of the UK. However, his contamination maps and levels were more in agreement with my HYSPLIT models and he also employed a source term of 10¹⁸ Bq, about twice that of the EPA. The HAST source term is about twice this in Cs-137 alone and so I believe a reasonably conservative assumption given the possibility of more than one HAST tank and the spent fuel pools being involved would to be to multiply Taylor’s contamination levels by a factor of 2 and apply this to the doses calculated by the EPA. Other more complex approaches are of course possible, but would require more time and support. Taylor reported surface Cs-137 contamination at approximately 2 x 10⁷ Bq/m². That is 20MBq/m². EPA 2016 found a maximum of 1 x 10⁵ Bq/m² so the factor to be used is 200. We can now apply this to a much larger population, since both Taylor 1999 and the HYSPLIT model show contamination of most of the Irish Republic. I will use a population for this contaminated area of 5 million persons. Table 8 gives the results for cancer yield.

Table 8 Absolute Cancer Yield in 50 years to 5 million persons exposed to the EPA calculated contamination levels and doses using the ECRR and ICRP absolute cancer risk coefficients.

Adjusted Taylor 1999 contamination dose	ICRP yield	ECRR yield*
600mSv	150,000	45 Million

* this represents an approximate doubling in the background cancer rate of 450/ 100,000 per year.

4.3 Heritable damage

A large number of peer-reviewed studies of congenital malformation in children born to parents exposed to Chernobyl contamination where ICRP calculated doses were around 1 mSv showed statistically significant increases in genetic effects. The issue was reviewed and discussed in Schmitz-Feuerhake et al [15]. It was pointed out that such effects are the consequence of low dose exposures to internal fission-products which have chemical affinity for DNA. The effects of such internal nuclides were discussed in Busby 2013 [16]. Above a certain quite modest dose, around 5-10 mSv, the heritable damage rates (as shown by end-points at birth) actually fall owing to miscarriage and fertility destruction [15]. This means that the result of the contamination of Ireland by a Sellafield accident would result in an increase in the congenital malformation rate but also a decrease in the birth rate. Those children who are born and seem healthy will have a higher risk of themselves having children with congenital conditions. The ICRP does not concede that there are any heritable effects in humans following exposures. This was a consequence of their apparently being no excess risk in the offspring of the Hiroshima survivors. But this finding was shown recently to be a result of epidemiological errors in the choice of comparison groups in the original study. It turns out that the control group for this study was abandoned in 1973 when effects began to show [17]. The issue is at the base of legal moves to have the ICRP basis of European Law re-justified in Ireland and other EU States [18]. The difference in prediction is shown in Table 9

Table 9 Heritable effects according to the ICRP and the ECRR

ICRP	ECRR
Heritable effect coefficient is 0.2% per Sievert based on effects in mice so at 5mSv effect will be 0.001% and undetectable.	At 5mSv there is predicted a 70% increase in infant (0-1y) mortality due to heritable effects but this will be saturated at this dose and further effects will be to decrease the birth rate. Both effects will be easily detectable and will result in the deaths of 5000 babies in the second year in a 5 million population.

5. Conclusion

The EPA 2016 report is unsafe and cannot be relied upon by the public, the media or administrators. The anonymous authors have shown extraordinary bias in every aspect of the report. They made elementary mistakes in their source term listing of isotopes, by including those which had short half-lives and will clearly not have been present in any significant concentration. They omitted a whole series of nuclides which are present in the tanks and the fuel pools. They choose a source term which is demonstrably too low based on available data, they choose a worst-case accident which involves only one HAST tank and only Caesium-137. They omit mentioning the spent fuel pools which are a highly likely site of a major coolant loss and subsequent fire or explosion. Their air modelling results are extremely unusual with implausibly narrow plumes, whilst a NOAA HYSPLIT model for the same day shows a completely different dispersion covering most of highly populated Ireland. Their surface contamination levels are 200 times lower than a previous computer model by Dr Taylor, which they must have had access to, and they fail to calculate the increased levels of cancer in the exposed population. This has been rectified here.

Historic releases from Sellafield to the Irish Sea have caused measurable increases in cancer and leukemia in coastal populations of Ireland. There is no doubt that the existence of Sellafield represents a potential catastrophic danger to the Irish Republic. A serious accident there could destroy the country and also most of Britain. As the Chernobyl accident effects showed, and the Fukushima accident effects will reveal (and in the case of Thyroid cancer have revealed) the ICRP risk model is unsafe for explaining or predicting health effects from such contamination. The Authors of the EPA 2016 report should be sanctioned in some way for producing such a travesty of the real picture, especially since they will have had access to the earlier study and modelling by Peter Taylor and the details of the COSYMA model employed by him.

Christopher Busby

August 17^th 2017

References

[1] Busby Chris (2006) Wolves of Water. A Study Constructed from Atomic Radiation, Morality, Epidemiology, Science, Bias, Philosophy and Death. Aberystwyth: Green Audit

[2] Taylor PJ (1999) A Major Accident Potential and Sellafield. The impact upon Ireland. Report for the case: Herr and Others vs. BNFL. Political Ecology Research Group Oxford. Unpublished but funded by the Irish State.

[3] Environmental Protection Agency (Ireland). Anon. (2016) Potential radiological impact on Ireland of postulated sever accidents at Sellafield. Dublin: EPA

[4] ICRP, International Commission on Radiological Protection. The 2007 Recommendations of the International Commission on Radiological Protection. ICRP-Publication 103, Ann ICRP 37. Oxford: Pergamon; 2007, Nos. 2-4.

[5] Busby C, Yablolov AV, Schmitz Feuerhake I, Bertell R and Scott Cato M (2010) ECRR2010: The 2010 Recommendations of the European Committee on Radiation Risk. The Health Effects of Ionizing Radiation at Low Doses and Low Dose Rates. Brussels: ECRR; Aberystwyth Green Audit.

[6] Turvey, F.J. & Hone, C., 2000. Storage of Liquid High-Level Radioactive Waste at Sellafield: An Examination of Safety Documentation. Dublin: RPII.

[7] Flowers (1976) 6^th Report on the Royal Commission on Environmental Pollution. London: HMSO

[8] Parker Justice (1978) The Windscale Enquiry Vol 1 Ch 11. London: HMSO

[9] Tickell O (2014) Leaked photos reveal massive radioactivity release threat. The Ecologist. http://www.theecologist.org/News/news_analysis/2611216/leaked_sellafield_photos_reveal_massive_radioactive_release_threat.html

[10] Alvarez R (2014) The hazards of high level waste in the Pacific North West. USA: Institute for Policy Studies

[11] SKB Forsmark Nuclear Waste Repository Environmental Impact and associated project documents application to the Environmental Court. Available from SKB and the Nacka Court.

[12] Stein, A.F., Draxler, R.R, Rolph, G.D., Stunder, B.J.B., Cohen, M.D., and Ngan, F., (2015). NOAA’s HYSPLIT atmospheric transport and dispersion modeling system, Bull. Amer. Meteor. Soc., 96, 2059-2077, http://dx.doi.org/10.1175/BAMS-D-14-00110.1

[13] Bandashevsky Yu (2011) Non cancer conditions and illnesses in areas of Belarus contaminated by radioactivity from the Chernobyl accident. In Busby C, Busby J, Rietuma D and de Messieres M—Eds Fukushima, what to Expect; Proceedings of the 3^rd International Conference of the European Committee on Radiation Risk. Lesvos 2009. Aberystwyth: Green Audit.

[14] Eckerman KF and Ryman JC (1993) Federal Guidance Report No 12. External exposure to radionuclides in air water and soil. EPA 402-R-93-081. Washington USA: EPA

[15] Schmitz-Feuerhake, Busby C, Pflugbeil P Genetic Radiation Risks-A Neglected Topic in the Low Dose Debate. Environmental Health and Toxicology. 2016. 31Article ID e2016001. http://dx.doi.org/10.5620/eht.e2016001.

[16] Busby Christopher (2013). Aspects of DNA Damage from Internal Radionuclides, New Research Directions in DNA Repair, Prof. Clark Chen (Ed.), ISBN: 978-953-51-1114-6, InTech, DOI: 10.5772/53942. Available from: http://www.intechopen.com/books/new-research-directions-in-dna-repair/aspects-of-dna-damage-from-internal-radionuclides

[17] Busby Christopher. Letter to the Editor on “The Hiroshima Nagasaki survivor studies. Discrepancies between results and general perception.” By Bernard R Jordan. Genetics. 2016; 204(4) 1627-1629

[18] Busby Christopher (2017) Child health and ionizing radiation: Science, Politics and European Law. Pediatric Dimensions. 2(3) 1-4 doi:10.15761/PD.1000150

August 27, 2019 - Posted by arclight2011part2 | Uncategorized