We recently saw reference online to an application by Cyclife to the Environment Agency To gain sight of the documents we had to ask for them under Freedom of Information as the “consultation” had ended. Now we only have until 1st March say the Environment Agency to make sure our comments are counted. What a stitch up. The application is asking the Environment Agency for a permit to house 40 shipping containers at a time at the Port of Workington on an area currently for the additional public car park. The shipping containers however are to hold radioactive scrap metal.
Why hasn’t this been advertised in the local and national press? What does Cumbria County Council have to say about it (they operate the Port of Workington) and does the local MP Mark Jenkinson even know about it. If he does know why hasn’t he informed his constituents of the application and allowed them to have a say? The Port of Workington regularly recieves £Millions of investment in new cranes and the like from the nuclear industry (actually public money) – there is no such thing as a free meal where the nuclear industry is concerned. The price of the nuclear industry’s faux largesse is too high.
Here is our letter to the Environment Agency.
Please do write your own letters of opposition ideally before March 1st – write to : RSR.Rotherham2.NE@environment-agency.gov.uk
Sent by email from Radiation Free Lakeland
February 25th 2021
Dear Environment Agency,
New non-nuclear site as nuclear storage: Port of Workington Cyclife EPR/WB3591DQ/A001
Application from Cyclife to the EA to store up to 40 shipping containers of radioactively contaminated scrap metal at the Port of Workington. Radiation Free Lakeland knew nothing of this application and only received the documents through a Freedom of information request. The public are being kept in the dark about the realities of “decommissioning” which includes recycling radioactive scrap metal.
Radiation Free Lakeland generally support the recycling of scrap metal. The nuclear industry however turns the principle of sustainability on its head by the so called ‘Best Available Technique” of recycling of radioactively contaminated scrap metal. In September 2009, Studsvik started up their £6 million scrap metal recycling plant at Lillyhall in Cumbria, taken over by EDF /Cyclife in 2016. The aim was to decontaminate and resell hundreds of thousands of tonnes of radioactive metal from the decommissioning of the UK’s nuclear plants. We urged the Nuclear Installations Inspectorate not to license the site in 2009 arguing that it was “irresponsible” to recycle radioactive scrap metal onto the open market. Along with other businesses on the Lillyhall industrial site we vehemently opposed the opening of the then Studsvik radscrap metal plant which was originally for 14 shipping containers of radscrap metal at any one time. Our concerns were ignored. The receipt of radioactive scrap metal to Lillyhall has increased over the decade and now there are around 40 radioactive shipping containers stacked one on top of the other, as well as numerous radioactively contaminated flat rail beds used to transport nuclear materials including spent fuel. The tsunami of radioactively contaminated scrap metal from decommissioning nuclear installations and waste transports has meant that the Cyclife plant is bursting at the seams and this is the reason why this application to store 40 shipping containers at the Port of Workington has come about.
UNDERMINING SCRAP METAL MARKET WITH RADIOACTIVELY CONTAMINATED MATERIAL
At the Dounreay Stakeholder Group last year David Broughton asked the following question “When I was on the Committee of Radioactive Waste Management I was informed that cleaned metal was being shunned by the non nuclear industries for re-use either because of real radioactive concerns or purely public relations issues. … I am interested to know if any of the cleaned metals from Dounreay are being recycled into either the nuclear engineering industry or the general engineering industry or being sent to scrap melting facilities. If they are there might be an economic case for the recycling process but if the cleaned metal is not finding any future use what is the economic reasoning for doing it? The cost comparison might be between the following scenarios: -cleaning and disposing in municipal landfill -cleaning and disposing in licensed Very Low Level Waste disposal facility -cleaning and selling to scrap melters -cleaning and re-use without remelt -no cleaning and disposal in Dounreay LLW disposal facility” Clearly even a former member of the Committee of Radioactive Waste Management which advocates that the Nuclear Industry adopt (so called) “Best Available Technique” cannot quite believe that radioactive scrap metal is being sold onto the open market. The answer from Dounreay Site Restoration makes it clear that recycling radioactive scrap metal is not for the benefit of the scrap metal industry as Cyclife’s public relations would have it, but for the nuclear industry who want to get shot of wastes to the wider environment. Response from Dounreay Site Restoration: “Thank you for your queries relating to the off-site diversion of metal wastes for treatment. As you are aware, DSRL has an ongoing requirement to demonstrate BPM (Best Practical Means) and this includes an obligation to review our waste routes and any associated opportunities. We are also acutely aware that the Dounreay LLW Disposal Facilities have a finite capacity and we wish to make sure we optimise the use of these facilities.” The response to David Broughton’s query from Cyclife was: “Both in Cyclife UK and Sweden the metal is sent on to conventional scrap merchants where the recycled metal is re-introduced to the conventional scrap market following the release process.” This in effect means that radioactive waste metal is being chucked out onto the open market for use in anything from underwire bra’s to flasks for your hot choc at lunch time.
The reason why the scrap metal market shuns metal recycled from the nuclear industry is because even with mixing the “cleaned” contaminated metal with clean metal, hot spots of radioactivity can remain and most scrap metal businesses do not have the wherewithal to install expensive radioactive monitoring equipment to check their source of metal. There are many examples of contaminated radioactive metals being found in consumer items as described in the document “Out of Control – On Purpose” from the Nuclear Information and Resource Service.
PLUTONIUM 500 METRES FROM RESIDENTIAL AREA OF WORKINGTON
The Cyclife Application acknowledges that there would be “hot spots’ in the metal housed in the shipping containers of up to 1000Bq/g
“5c – Chemical and physical details of the radioactive waste -The waste will consist of contaminated solid metals either awaiting treatment at the MRF or following treatment at the MRF and awaiting incineration at Cyclife Sweden. The waste will be of nuclear origin, from either decommissioning activities or routine arisings and have an average specific activity of less than 100 Bq/g with a maximum for a hotspot of 1000 Bq/g.”
There is however no guarantee that the limit in the shipping containers would be the already generous 1000 Bq/g as described by Cyclife. In reality there is likely to be undetected heavy radioactive material in the containers source and some of that could well be in powder form which is a lot more risky to contain (near a residential area) than solid lumps of metal.
We assume that Cyclife are saying that the “hotter’ metals would be shipped to their sister plant in Sweden “The Cyclife MRF can also be constrained by availability of downstream routes, such as incineration routes that have monthly activity limits, or shipments of waste to Sweden for melting”
The table of radionuclides that Cyclife are applying to the EA for storage at the Port of Workington includes Plutonium. (from REDACTED Application-New-Accumulating radioactive waste.pdf)
This would be 500 metres from the nearest residential areas in Workington. This is unacceptable.
in 2019 Cyclife applied to increase radioactive effluent from their Lillyhall site. This was due to a fault on the metal containers holding the radioactive scrap metal, a fault which allowed ingress of water. It is this ingress of contaminated water that Cyclife wanted to pour down the drains at Lillyhall. We wrote opposing this saying “Cyclife should not under any circumstances be rewarded for their failure to stop ingress of water into the containers of radioactive scrap metal at Lillyhall. Rather than being rewarded with an increase in the radioactive discharge to the drains at Lillyhall Cyclife (EDF) should be prosecuted for their failure to protect the public.” We are not sure of the outcome of this. Is Cyclife pouring radioactive liquids down the drains? Clearly if Cyclife are given an Environment Agency permit to “store” radioactive waste at the Port of Workington the POW would soon become a full blown nuclear licensed site with all that entails. The POW could become a virtual no go area for other businesses as is happening at Lillyhall with the withdrawal of other businesses from the site over concerns at the increasing nuclearisation. A £45Million cheese factory planned for Workington in West Cumbria did not go ahead in 2007, Studsvik’s plan to build its radioactive scrap metal recycling plant at Lillyhall was cited as a major concern. This has been ongoing with new evidence emerging of the nuclear blight inflicted on Cumbria’s businesses over decades “A record in the files of the UK atomic energy authority has shown Rowntree was also concerned about the safety of produce from its factory in nearby Egremont.” Rowntree eventually pulled out of Cumbria.
SMALL BLUE BUTTERFLY -HABITAT -Environmental assets
The Port of Workington site is largely industrial in nature. However there is Small Blue Butterfly habitat and species rich grassland. The Small Blue is a UK Protected Species, a UK Biodiversity Action Plan Priority Species and Species of Principal Importance in England.
We believe a large part of the Port is likely to constitute the UK Priority Habitat of ‘Open Mosaic Habitats on Previously Developed Land’. This Habitat is often of significant value for a wide range of invertebrate species. The Port Estate is a vital habitat for the endangered Small Blue Butterly.
RIVER DERWENT and BASSENTHWAITE LAKE SPECIAL AREAS OF CONSERVATION – Radioactive Impacts from Drainage.
The Environment Agency should have regard to Issues for Cumbria County Council’s Habitats Regulations Assessment which includes consideration of potential indirect impacts on the River Derwent and Bassenthwaite Lake SAC, even though the boundary is upstream of the site. Contamination of the river downstream of the SAC boundary would be likely should this go ahead. Within 1.2km of the Port are the River Derwent and Bassenthwaite SAC; River Derwent and Tributaries SSSI, Oldside County Wildlife Site (CWS) is within 730m; Barepot CWS is 1.4km; Hazel Gill CWS is 1.5km; Hallguards CWS is 1.6km; Siddick Pond SSSI/Local Nature Reserve/UK Priority Habitat of fen, marsh and swamp 450m; UK Priority Habitat of coastal habitats above high water lies 620m away; and three separate areas of Ancient Woodland/UK Priority Habitat of semi-natural woodland – Stainburn Woods, Hazel Gill Wood and Calva Brow Wood – are 1.6km, 1.7km and 1.8km away respectively.
“If you placed a teacup sized piece of high-level waste [the highly contaminated liquor which results from the reprocessing of spent nuclear fuel, a practice which has now largely ceased] in the middle of football pitch, you and everyone in the stadium would be dead before you left the centre circle.”
Karl Connor, spokesperson for Sellafield, BBC Radio 4, 7/1/15 ‘How to dismantle a nuclear power station’
The unusually honest quote above from a Sellafield spokesperson above and recent article by Pete Wilkinson “Low Level Radiation – a Game Changer for the Nuclear Power and Weapons Industries” illustrates how the public have been kept confused about the risks of radioactive wastes and their dispersal to the wider environment. “Particulates of plutonium and uranium, invisible to the naked eye, produce energetic and highly interactive emissions that, while presenting little danger when outside the body, can present a serious internal hazard when inhaled or ingested. They represent a small ‘dose’ but can have a disproportionate effect on health if the body doesn’t manage to rid itself of the particle. The reality is actually ‘small dose, large risk’,…”
Radiation Free Lakeland urge the Environment Agency to refuse this application from Cyclife. The Nuclear industry’s decommissioning program is out of control and should be halted with a view to halting the continued dispersal of radioactive wastes to the wider environment. “Dilute and Disperse” as a concept has been proved to be scientifically erroneous. There is no “away”.
- Regulators should not be facilitating the dispersal of Radioactive Scrap Metal to the Open Market.
- Cyclife acknowledge “hot spots” in the radioactively contaminated metals
- The Port of Workington is just 500 metres from residential areas in Workington
- Likely Contamination of the Derwent and Bassenthwaite SAC / Small Blue Butterfly Habitat
- Health Damage to the Public
For the reasons above Cyclife should not be given permission to store 40 shipping containers of radioactively contaminated scrap metal at the Port of Workington
on behalf of Radiation Free Lakeland
Studsvik Safety Breaches https://www.robedwards.com/2010/11/ban-on-radioactive-waste-shipments-after-safety-breaches.html
David Broughton is a Chartered Engineer and a Member of the Institution of Mechanical Engineers. Recently retired from UKAEA he worked at Dounreay, Caithness from 1981. He has 26 years experience in professional engineering and management of complex nuclear projects. He was responsible for Dounreay’s major radioactive waste management projects. These included new low level waste disposal facilities, new intermediate level waste encapsulation and storage facilities, the future retrieval of waste from the Dounreay shaft and the current shaft isolation project. He is experienced in both engaging stakeholders in projects that have many options and technical issues to consider, and guiding projects through the regulatory and planning processes. https://www.wired-gov.net/wg/wg-news-1.nsf/0/C79E1EAF2B68BD4C80257380005181C9 https://www.dounreaystakeholdergroup.org/wp-content/uploads/2020/06/DSG2020C029_Waste-Recycling_clarification-for-action-M01_A002.pdf
Out of Control – On Purpose NIRS https://www.nirs.org/wp-content/uploads/radwaste/outofcontrol/outofcontrolreport.pdf
Letter regarding faulty containers and water ingress – Lillyhall https://mariannewildart.wordpress.com/2019/03/01/radioactive-scrap-metal-plant-at-workington-wants-to-increase-radioactive-effluent/
Cheese Factory Scrapped – https://www.timesandstar.co.uk/news/17050627.final-hurdle-for-studsvik-plant/
Small Blue Butterfly http://www.cbdc.org.uk/uploads/cbeb/statements/CBEB-SmallBlue.pdf
River Derwent and Bassenthwaite SAC https://sac.jncc.gov.uk/site/UK0030032
Pete Wilkinson https://webcache.googleusercontent.com/search?q=cache:nhAHszpdBuoJ:https://yorkshirebylines.co.uk/low-level-radiation-a-game-changer-for-the-nuclear-power-and-weapons-industries/+&cd=1&hl=en&ct=clnk&gl=uk