There is a short consultation by the Environment Agency going on now which has been described by the BBC as a proposed “New permit for Sellafield as discharge levels drop”. This is pure Sellafield PR spin.
Sellafield says its levels of discharge are dropping because they are no longer reprocessing (dipping spent fuel rods in millions of tonnes of acid and dissolving them to retrieve uranium and plutonium) so they have asked the Environment Agency to cut them some slack ( they have too much slack already!)
So to put in a broad brush, Sellafield say they should not be hampered by now defunct (?!) regulations to nominally protect the public or have to report to the Environment Agency as their routine discharges are lower (are they though?) . However it is clear that their accidental discharges are becoming routine!
This new permit if given the go ahead would give Sellafield carte blanche to pollute our environment even further.
The consultation ends on the 1st Dec – so far only two consultation responses are visible and they are both very happy for Sellafield to be given free rein by the regulators.
I have written a very quick consultation response on behalf of Radiation Free Lakeland and would urge other NGOs and individuals to do the same. Our response is below. If we have time to add to this with more info before the 1st Dec ‘deadline’ then we will.
You can write in the online questionnaire as I have done below – or email them at firstname.lastname@example.org
Submitted to Sellafield Radioactive Substances Activities (RSA) Permit – Draft DecisionSubmitted on 2019-11-23 17:09:30
How we will use your information
Section 1: About you
1 What is your name?
2 What is the organisation or group that you represent?
Radiation Free Lakeland
Section 2: Have your say
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?
Sellafield has been discharging radioactive wastes from the site for many decades now.
Any further release of radioactivity from the site is cumulative and to be avoided.
For Sellafield to be seen to be congratulating itself on reducing discharge to the environment is both sickening and meaningless. Even within this short 8 week consultation period there has been a serious accidental release of liquid radioactive wastes to the ground beneath the Magnox Swarf Silo.
This is just 1 mile from the boreholes from which West Cumbria is now receiving much of its freshwater. This is unacceptable.
Dilute and Disperse: Sellafield has refused to share its freshwater abstraction licenses to enable the public supply of freshwater to be sourced from R1 quality water from rivers and lakes- but is more than happy to dispose of radioactive wastes diluted by those rivers and lakes, into the public domain.
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?
Quarterly and Annual plant notification levels and monthly ‘triggers’ are inappropriate. The public must be assured that their HOURLY and DAILY safety is the top priority rather than Sellafield’s convenience in acting as judge and jury in whether or not to ‘notify.’
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?
Question 3 :
Decommissioning in practice means that Sellafield is increasingly exporting its nuclear activities onto previously nuclear fee sites
This is unacceptable and increases the danger to the public from nuclear wastes previously discharged from the Sellafield site but now being discharged from Lillyhall Landfill, Cyclife, Shortridge and the Energy Coast Laundry, with even the washing of Sellafield site construction mats in the streets of Workington. Lillyhall landfill pre 2008 only accepted Naturally Occurring Radioactive Material now it accepts nuclear wastes from across the UK and even beyond our borders. All the other sites were previously nuclear free.
The UK government policy and guidance for nuclear sites falls far short of the reality This is from the UK Strategy for Radioactive Discharges: “3.4.7 It is important to ensure that discharge reductions are not achieved at the expense of unacceptable increased accident risk, due, for instance, to storage of greater quantities of waste on site, for a longer time, in unsatisfactory conditions. The systems of control for nuclear safety and nuclear waste management in the UK would not, in any case, allow the risks from such factors to increase unacceptably.” The systems of control are not adequate now. To reduce them further is entirely unacceptable in terms of likely harm to the public and to the environment. The United Kingdom is a signatory to the Convention for the Protection of the
Marine Environment of the North East Atlantic . The reductions in notification and control is in direct contravention of the international OSPAR convention which seeks to reduce radioactive discharges to the marine environment to zero. With regards the EU, the releases are subject to Euratom Basic Safety Standards. Since releases to the Irish Sea affect the Republic of Ireland they must conform to the BSS if Britain is still in the Eu and the Espoo Convention for cross boundary releases. Any increases are unacceptable, indeed any releases are unacceptable.
We vehemently oppose the :
• Removal of site limits and quarterly notification levels where discharges have fallen below significant levels, in terms of quantity discharged and resulting impact. • Significant reduction in headroom in site limits and quarterly notification levels where future discharge projections allow.
• Replacement of annual plant limits with annual plant notification levels to enable Sellafield Limited to optimise discharge routing and the effective use of abatement plants.
All the above is in direct conflict with the UKSRDS09 laid out UK Government policy on radioactive discharges: that the unnecessary introduction of radioactivity into the environment is undesirable, even at levels where doses to humans and other species are low and, on the basis of current knowledge, are unlikely to cause harm.
4 Does the proposed tritium limit for disposals in CLESA raise any concerns for you? If so, what are these concerns?
We have already opposed the proposal to increase the tritium limit fivefold for Lillyhall landfill.
Similarly we vehemently oppose any increase in the levels of tritium to be dumped in Sellafield’s own landfill. The most comprehensive report on tritium was published by the UK Government’s senior Advisory Group on Ionising Radiation (AGIR, 2008).
This report strongly recommended that tritium’s hazard (ie, its radiation weighting factor) should be doubled from 1 to 2.
However other scientists (Fairlie, 2008; Fairlie, 2007a; Fairlie, 2007b; Melintescu et al, 2007; Makhijani et al, 2006) have presented evidence for even larger increases in tritium’s radiotoxicity, including the US EPA (2006) which recommended a 2.5 fold increase in hazard.
Dr Ian Fairlie an expert on radiation in the environment points out that “in its elemental form, tritium diffuses through most containers, including those made of steel, aluminium, concrete and plastic. In the oxide form, tritium is generally not detected by commonly-used survey instruments”. Tritium is uniquely dangerous to human health and to the environment. The plan to discharge increased levels of tritium to landfill on the Sellafield site is unacceptable.
We draw the Environment Agency’s attention to the fact that boreholes just one mile away from Sellafield are now providing a substantial amount of West Cumbria’s drinking water. We believe this practise of taking water from boreholes so near to Sellafield is intolerable with regards public health. Within the time scale of this consultation there has been (routine) accidents involving radioactive liquids released to ground water. Sellafield has so far refused to share its enormous freshwater abstraction licenses with the public even though Sellafield operations are now increasingly being carried out using the public’s stressed water supplies offsite. (eg Cycliffe, Energy Coast Laundry and washing Sellafield construction mats in Workington).
5 Is there anything that is inaccurate or missing in the draft decision document? If so, please provide details.
The draft decision document fails to acknowledge the cumulative dose to the public from Sellafield’s decades long discharges.
The document fails to acknowledge the fact that there is no safe dose of radiation to the public.
The document fails to acknowledge that all dose is cumulative.