Reply to UK government’s nuclear dump consultation – STOP Undersea Nuclear Dump NOW!

MAY 3, 2023 BY MARIANNEWILDART

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

1 March 2023 Notes from Radiation Free Lakeland sent by email to:RSNDPolConsult@beis.gov.uk 3rd May 2023

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 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 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:…………………………………………………………………………………………..

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 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………………………………………………………………

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.