Thanks to Cumberland Echo – the first media to flag Radioactive Scrap Metal plan for Port of Workington

The following is an article which first appeared in the Cumberland Echo,
Workington Port to house radioactive scrap metal?
Written by John Walsh   
Friday, 05 March 2021
workington port.png

A controversial plan to house up to 40 shipping containers, with radioactive scrap metal inside at the Port of Workington, has sparked protests from an environment group.Radiation Free Lakeland claim this is being slipped through without any previous publicity or serious discussion on the subject. RFL only got sight of the relevant documents under Freedom of Information and following a letter to Allerdale Borough Councillors were told by one that they knew nothing of the plan. A letter to Workington MP Mark Jenkinson has brought no reply.Prominent RFL member Marianne Birkby said: “This seems to be yet another taboo nuclear waste story.” In their letter to Allerdale councillors RFL said: “We have only recently found out about an application by Cyclife/EDF to permanently house up to 40 shipping containers at a time of radioactive scrap metal at the Port of Workington.  We suspect this application has been made above the heads of councillors. “The deadline for the official consultation has passed and it was only through a Freedom of Information request that we were able to access the documents relating to the application.  The Environment Agency said we had until March 1st to comment.  This is outrageous.   “We hope that councillors will ask to be able to at least discuss and vote on this new development which would have far reaching consequences for public health and confidence in the Port of Workington.”The group say that 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. 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.   

 The Cyclife Application acknowledges that there would be “hot spots’ in the metal housed  in the shipping containers of up to 1000Bq/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.   
RLF conclude: “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 Port of Workington is wholly owned and operated by Cumbria County Council, which is the Statutory Harbour Authority, and is an independent Municipal Port established in 1975. 
Skyline of Workington from the shoreline hills photo by Andy V Byers

The following letter is from the Nuclear Free Local Authorities to the Environment Agency

1st March 2021 NFLA response to new non-nuclear site as nuclear storage: Port of Workington Cyclife

EPR/WB3591DQ/A001

Dear Environment Agency Project Office,

We were recently made aware by the group Radiation Free Lakeland of an application to permanently store 40 shipping containers, which includes within them low levels of radioactively contaminated scrap metal at the Port of Workington in Cumbria. Whilst the closing date for the environmental permit has passed, we understand you are accepting comments until the 1st March.

For your information, the NFLA is a local authority group which is made up of Councils from across England, Scotland, Wales, Northern Ireland and the Republic of Ireland. Its Steering Committee and Secretariat are based in Manchester. NFLA raises legitimate concerns and issues over all aspects of nuclear policy and energy policy in order to assist local government in meeting its commitment to sustainable development, energy policy development, environmental protection and public safety.

1. Concerns over radioactive scrap metal

The NFLA have been concerned for many years over the large international market that remains with the recycling of scrap metal from the nuclear sector, and the potential for such material, containing low levels of radiation, returning to be used in steel for consumables or buildings.

It is alarmed to find out in this case that this market is growing exponentially from the EDF / Cyclife (formerly Studsvik) recycling plant at Lillyhall in Cumbria.

The plan for EDF / Cyclife appears to be that the plant is used to decontaminate and resell hundreds of thousands of tonnes of radioactive metal from the decommissioning of the UK’s nuclear plants. In 2009, authorisation was given to license the site originally for 14 shipping containers of radioactively contaminated scrap metal at any one time. This work has clearly expanded greatly, there are now 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. This work seems so plentiful from the decommissioning of nuclear installations and national / international waste transports that the Cyclife plant cannot cope with demand and is requesting to store 40 shipping containers at the Port of Workington.

This application raises several areas of concern.
Firstly, the shipping containers will only be around 500 metres from a residential area.

The Cyclife Application acknowledges that there would be “hot spots’ in the metal housed in the shipping containers of up to 1000Bq/g –

1

“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.”

Storing such metal so close to a residential area is unacceptable and NFLA urges the Environment Agency to reject this application.

2. Contaminated steel going on to the open market

Secondly, NFLA is concerned about the increase in radioactively contaminated metal entering the scrap metal market.

NFLA is interested to note a comment made in the Radiation Free Lakeland response of a query from former CORWM member David Broughton to the Dounreay Stakeholder Group in 2020, and the Cyclife response to it.

Mr Broughton asked: “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 answer from Dounreay Site Restoration was as follows: “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 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.”

As such therefore, low levels of radiation in the scrap metal could be going on to the open market. For NFLA there has always been concerns around this, as ‘hot spots’ of radioactivity can remain for which conventional scrap metal businesses do not have the technical knowledge to remove.

3. Radioactive blight

Thirdly, the increase in metal entering the decontamination process will inevitably increase the discharges of radionuclides into the environment.

NFLA note with alarm of Radiation Free Lakeland’s overview that, 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.

At the time Radiation Free Lakeland wrote to the Environment Agency opposing this application as: “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.”

NFLA would be interested in the outcome of this application.

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NFLA is concerned that, should the Environment Agency permit this store at the Port of Workington it will be the start of a process that could end in it having to become a nuclear licensed site. This may put off other businesses investing in the area.

4. Environmental concerns

Fourthly, there is a specific biodiversity concern associated with the Workington site.

Whilst the Port of Workington site is largely industrial in nature, there is a Small Blue Butterfly habitat and species of rich grassland close to it. The Small Blue Butterfly is a UK Protected Species, a UK Biodiversity Action Plan Priority Species and a Species of Principal Importance in England. It is also expected that a large part of the Port could be made into a 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.

As such, the NFLA is concerned about the Port being a storage for low level radioactive materials with such rare and important invertebrate species within the local area. It calls on the Environment Agency to consider these matters carefully when considering this application.

5. Conclusion

Whilst the NFLA has not had a lot of time to consider this application, there are several issues of concern around it. NFLA is particularly alarmed about the exponential increase in recycled metal that is being created by the Lillyhall site and placing 40 shipping containers of such material at Workington Port appears to be spreading this radiation issue to another site. Given the level of work, will Cyclife stop at just 40 containers, or will further applications come for an increase in this number over time? This could move a commercial port into having to be considered over time in being a nuclear licensed site if not curtailed now.

This is very much an example of the ‘dilute and disperse’ practices that are increasing within the nuclear industry. For the NFLA, the policy should be rather to ‘concentrate and contain’ such materials at source. The Environment Agency should not be accepting this application and rather should use it as an example for promoting best practice and the protection of the wider environment.

NFLA is concerned how close residential areas are to these contaminated shipping containers and for the protection of a rare butterfly species, other rare invertebrates and the close proximity of sites of special scientific interest, as well as potential leakage to other watercourses.

For such reasons NFLA argue Cyclife should not be given permission to store 40 shipping containers of radioactively contaminated scrap metal at the Port of Workington.

Yours sincerely,

Sean Morris, NFLA Secretary
On behalf of the UK & Ireland NFLA Steering Committee

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