Energy and Climate Change CommitteeWritten evidence submitted by Tim Deere-Jones (NUC 33)

Preface

This Submission of Evidence to the Select Committee is based on work carried out over the last two years for a series of Consultation Responses made with specific regard to applications by NNB Genco to discharge liquid radioactive wastes from the proposed new Hinkley C Reactors on the north Somerset coast of the Bristol Channel.

Production of those Consultation Responses (hereafter referred too as Previous Consultation Responses) was jointly sponsored and funded by the UK and Irish Nuclear Free Local Authorities, CND Cymru, Friends of the Earth Cymru and the Stop Hinkley campaign. Those organisations have given their permission and support for the use of some of the research data, contained within the Previous Consultation Responses, to produce the following Submission to the Select Committee.

Readers will note high frequency reference to environmental and radiological work carried out in the Bristol Channel in the context of proposed new build NPS in that sea area. This has occurred in the context that the proposed Hinkley Point C nuclear power station is the first to be the subject of a development proposal.

However it is the intention of this Submission to address issues relevant to the entirety of the UK Nuclear New Build programmes and its possible impacts upon the entire range of UK marine and coastal environments and the human populations which will be exposed to radioactivity in those environments as a result of the discharge of radioactive wastes to sea from proposed new build NPS.

Tim Deere-Jones
Marine Pollution/Radioactivity Consultant

November 2012.

Principal Conclusions

This Submission to the Select Committee identifies:

(a)Failures of scientific rigour in the scientific and technical contribution of both Developers and Regulators to the consideration of issues relating to radioactive waste discharges to the marine environment from proposed Nuclear New Build, leading to.

(b)A series of major flaws and data gaps in the understanding of the behaviour and fate of radioactive wastes discharged to the range of UK marine environments (sections 1 to 4).

(c)A series of major failures and inadequacies in the programmes put in place to monitor and analyse the behaviour, fate and concentrations of radioactivity in the range of UK marine environments (sections 5 to 9).

(d)Draws attention to the fact that those data gaps, failures and inadequacies must inevitably militate against the construction of accurate hypothetical models of radiation exposure pathways and dose rates to the public (sections 9 to 18).

(e)And the absence of discussion of post LOCA highly radioactive pollution of marine waters (Fukushima) (section 19 and Annex 1).

This Submission Therefore Concludes That:

1. In the context of the conclusions listed above, proposals and decisions to proceed with Nuclear New Build developments are premature in the extreme.

and that

2. No decisions on UK Nuclear New Build, and subsequent discharges of nuclear wastes to the UK marine environment should be taken until the issues set out in this Submission have been settled.

1. The original hypothesis (Nuclear Industry and UK Government) for the behaviour and fate of sea discharged radioactive wastes.

1.1 In 1952, when the first sea pipelines for the discharge of liquid nuclear waste were commissioned at Windscale/Sellafield for the commencement of the UK’s programme of discharges of radioactive wastes to sea, there was no scientific understanding of the behaviour and fate of radioactive wastes in the marine environment because such a programme had never before been undertaken. In the absence of any scientific data, the UK Government and the Nuclear Industry, in accord with international nuclear bodies such as the IAEA, appear to have adopted a hypothesis for the behaviour of radioactive wastes in coastal and marine environments.

1.2 The hypothesis postulated that long lived, non-soluble nuclides such as the alpha emitting actinides like Plutonium (Pu) and Americium (Am), would become adsorbed to the surface of sedimentary particles in the marine water column, sink to the sea bed and there remain permanently bound and immobilised in seabed (subtidal) sedimentary deposits isolated from human populations and their immediate environment. Less conservative nuclides, such as Caesium (Cs), would dilute and disperse through the water column until they reached “background” concentrations.

1.3 This hypothesis supported the adoption of the proposal that the behaviour of radioactive wastes discharged into the marine environment was such that “they can be diluted and dispersed so that the radiation to which any single individual would be subjected would be negligible”. (Ref 1)

1.4 It was upon this hypothesis that the scientific and ethical justifications for the sea disposal of radioactive wastes were based and permission for the discharge of radioactive wastes from Sellafield was granted. In later years, as the UK’s civil nuclear programme continued to evolve, the hypothesis also provided the scientific justifications for the sea disposal of radioactive wastes from the UK civil nuclear power stations, the great majority of which were sited on (or close to) the UK coastline and provided with pipelines which facilitated the sea disposal of radioactive wastes.

1.5 N.B. Sea discharged radioactive wastes from reprocessing sites and civil reactors are generally referred to as “liquid” or “aqueous” wastes but in fact they are not composed entirely of liquid matter. Although, in terms of bulk or volume of discharge, they may consist of a high percentage of radioactively contaminated liquids such as secondary coolant, such discharges also contain a range of radioactive solid particles including pieces of irradiated fuel, metallic particles from reactor internals, pieces of radioactively contaminated discharge pipe line and other items. The records show that the majority of these items are micro-particles small enough to be suspended in discharge streams and the water column of receiving water bodies.

1.6 The hypothesis appears to have been the basis for subsequent programmes of marine environmental sampling, analysis and monitoring of the behaviour and fate of sea discharged radioactivity in the marine environment. These marine environmental monitoring programmes have subsequently been the source of the basic data inputs to the hypothetical models of human population exposures to, and doses of, radioactivity from the marine environment (via a number of exposure pathways).

1.7 However, the real scientific ignorance of the subject was so great that, in 1958, the UK industry and regulators were forced to admit that the whole issue of sea disposal of liquid radioactive waste, particularly in the Irish Sea, had really been an enormous research project. (Ref 2)

Despite this admission, the original simplistic hypothesis appears to have remained the dominating historical justification for the discharge of liquid radioactive wastes to sea.

1.8 I have not found any over-arching statement from industry or UK government agency or regulatory bodies that has subsequently denied, revised or refuted this basic hypothesis. Thus, it is to be presumed that

(a)the hypothetical model has continued to be the basis of the UK nuclear industry’s and the UK Government and Government Regulatory Agency position with regard to the behaviour and fate of liquid radioactive wastes discharged into the UK marine environment; and

(b)no evidence accrued as a result of the post 1952 research project has been of sufficient significance to change the industry, government or regulatory agency position on the discharges of radioactive wastes to sea.

2. The current academic understanding of the behaviour and fate of both soluble and non soluble radioactive materials in marine environments.

2.1 According to the International Council for the Exploration of the Seas, the fate of pollutants discharged to sea is dependant on the environmental conditions at the time of release and for a few months afterwards. (Ref 3)

It is now understood that soluble nuclides such as Caesium 137 can remain in solution in the seawater after discharge to sea, and may thus travel in the water column for both extended distances and time scales and still be detectable.

2.2 The marine distribution of Caesium 137, discharged from the Sellafield sea pipes, has been widely mapped in order to study its distribution and dilution in the Irish Sea and further afield.

This work demonstrates that soluble radio nuclides discharged to sea can be detected many hundreds of kms distant from source. Furthermore, this work demonstrates that such “soluble” radioactivity spreads out of one distinct sea “area” (the Irish Sea) and into other more distant sea areas (eg the Southern North Sea). (Ref 4)

2.3 Other work has demonstrated that insoluble radionuclides (such as those produced by the irradiation of uranium and other artificial elements), discharged to sea from the Sellafield site, can also travel hundreds of kms from source. Radio nuclides, such as Plutonium 239 (with a half life of 24,110 years), adsorb strongly to the outer surface of particulate matter suspended in the water column wherein they are available for transport in the water column (over extended distances and time scales) and subsequent deposition into fine sediment deposits such as estuarine and coastal mudflats and salt marshes. (Ref 5)

2.4 The 2009 monitoring of Irish Sea sediments, records the presence of the Sellafield derived actinides Plutonium, Americium and Curium isotopes in fine sediment deposits (salt marshes and mudflats) on the Irish Sea coasts of Cumbria, Lancashire, S.W. Scotland, North Wales and Northern Ireland. (Ref 6)

UK Marine monitoring reports invariable allude to the detectable presence of Sellafield derived Plutonium as far away as the Bristol Channel and the Southern North Sea.

2.5 Thus there is no doubt that both soluble and insoluble radio nuclides discharged to sea are physically adapted to being transported for:

(a)extensive time periods; and

(b)over extensive distances from point of discharge.

2.6 Thus there is now conclusive evidence to demonstrate that the original proposed model was over optimistic and simplistic with respect to the distribution of both soluble and non-soluble nuclides.

3. Radioactivity and Marine Sediments

3.1 There is now a strong and long established consensus that some radioactive materials closely associate with fine sediment particles suspended and/or deposited in marine/coastal/estuarine environments (by adsorbing to the outer surfaces of the particles). This is particularly noteworthy in the case of actinide/alpha emitters such as those listed in 2:4 above. (Refs 7&8)

3.2 One of the basic principles of marine sedimentary science is that fine particle material suspended in the water column is available for transport in marine water columns prior to eventual deposition into various environments under the influence of a range of parameters including the mixing of fresh and saline waters, flocculation and a range if other hydrodynamic factors.

Such deposition is shown to occur in both estuarine sediments, estuary fringing mudflats and salt marshes (Ref 9) and some offshore sediment deposits which are usually formed under the influence of slack tide and/or gyre type phenomena.

3.3 However such deposited material is subject to a number of phenomena (trawling, earthquakes [surprisingly frequent in UK coastal waters], storm surges and surface waves) that have an influence on shallow water sea beds and are capable of re-suspending and re-injecting sediment into the water column where it is once again available for further transport.

Heavier suspended particles and/or flocs (aggregates of suspended particles) have been shown to deposit out of the water column relatively quickly. However, finer particles may travel through the marine environment for more extended periods before deposition.

3.4 Because a given volume of finer/lighter particles have a relatively greater surface area than the same volume of coarser/heavier particles and because the fines tend to preferentially gather in the least dynamic, more low energy, sheltered and inshore environments it is usually the case that:

(a)samples taken from mudflats and salt marshes in such low energy environments consist of these finer particles; and

(b)these fine sediment deposits are generally found to contain the highest concentrations of adsorbed radioactivity and other pollutants.

3.5 Thus, in the Wigtown Bay/Cree Estuary area of the Solway coast of Scotland, monitoring of Sellafield derived radioactivity is carried out several inter tidal sites (ie estuarine shoreline sites which are exposed at low tide). This work demonstrates that the concentrations of the Sellafield derived actinides Plutonium (Pu) 238, Pu 239, Pu 240 and Americium 241 sampled at more “inner” estuary/bay (fine sediment) sites are markedly elevated over those sampled from the stony bottomed Garlieston Harbour at the mouth of the estuary/bay. (Ref 10)

N.B. Detailed reading of Ref 10 (and indeed any of the various aquatic environment monitoring reports) shows this to be a common feature through the entirety of the UK coastline.

3.6 The paragraphs above thus provide evidence for:

(a)the transport of non soluble nuclides away from the point of discharge and into distant environments; and

(b)the fact that non soluble nuclides become more concentrated in estuarine (fine) deposits as a result of their adsorption to the outer surface of fine sediment particles and their subsequent deposition in fine sediment deposits; and

(c)the fact that non-soluble nuclides are not isolated from human populations and their immediate environment by being “locked” into sea bed sediment deposits (as the original justifying hypothesis had proposed), but have been a long term feature along estuarine shorelines where they are thus in the exposed intertidal environments situated adjacent to local populations.

4. Mechanisms and factors of reconcentration of radioactivity in the marine environments

4.1 Studies conducted in the laboratory and in the marine environment have demonstrated that Irish Sea surface micro layers (only thousandths of a millimetre thick) become enriched with fine particle sedimentary material and their adsorbed radioactivity. These studies have shown Irish Sea micro layers to be enriched with non soluble Plutonium and Americium (associated by adsorption to fine sediment particles) by factors of four to five (relative to concentrations found in the ambient seawater) (Ref 7)

4.2 The above referenced study also reported on investigations of the enrichment of marine aerosols (generated by bubble production in breaking waves and the surf line) with non soluble nuclides (associated by adsorption to fine sediment particles).

The study reported enrichment factors (EFs), relative to ambient seawater, of:

(a)EF 291 for Pu 238.

(b)EF 347 for Pu 239.

(c)EF 347 for Pu 240.

(d)EF 583 for Am 241.

In marine aerosols generated 10 km offshore of the Sellafield sea discharge pipelines.

4.3 Other studies report EFs (relative to ambient seawater) of 812 for Am 241 in aerosols generated in the inshore surf zone along the Cumbrian coast. It is reported that this evidence implies that coastally generated aerosols may produce higher enrichment factors than those produced in more open sea environments (because of the higher ambient fine sediment loadings of inshore waters) and it was estimated that about 2 curies of Pu 239 and 240 had been transferred from the sea to the land over a 14 year period. (Ref 8)

4.4 There is a marked paucity of study of other potential marine enrichment mechanisms such as fog production, evaporation from sea surfaces and evaporation from exposed mud flats. However it has been calculated that algal blooms in the open sea may concentrate Plutonium by factors of up to 26,000 relative to concentrations in ambient sea water. (Ref 11)

4.5 It has also been demonstrated that soluble nuclides such as Caesium 137 become enriched in wet marine sediments in UK coastal and inshore waters (relative to concentrations in ambient marine water).

Thus, monitoring carried out in the marine environment adjacent to the Hinkley Point discharge pipeline reports:

(Ref 12)

4.6 It is thus a well reported and well understood fact that there are mechanisms of re-concentration in the marine environment for both the soluble and non-soluble radioactive wastes discharged into the sea and as a result of this phenomena there are sites where radioactive materials of both types accumulate/reconcentrate to levels many times higher than ambient sea water.

In this context, the original simple hypothesis that discharged liquid radioactivity will dilute and disperse until it reaches “background” concentration is now shown to be both simplistic and deeply flawed.

4.7 It is plain that the behaviour and fate of sea discharged radioactive wastes is actually far more complex than originally postulated and that a number of environmental parameters provide the opportunity for a range of intermediate and long term re-concentrations of radioactivity in inshore and coastal environments and media (sediment deposits, seaspray and aerosols)

5. Monitoring radioactive wastes discharged to the marine environment

5.1 As explained in earlier sections (above) the annual monitoring programmes carried out by government agencies remain rooted on the simplistic hypothesis that discharged radioactive wastes will dilute and disperse in the marine environment or remain bound to immobile marine sediments. Thus the major investigative effort is focussed on “near field” impacts close to the point source of discharge where, according to the hypothesis, radioactivity concentrations are likely to be at their highest and exposure of the public at its greatest.

5.2 Thus, contemporary monitoring reports such as “Radioactivity in Food and the Environment, 2010. (RIFE 16)” still explain that

NB these clauses are listed in their chronological order of presentation, which demonstrates their order of priority. Furthermore, the use of the words “background concentrations” in the third clause implies an expectation of very low levels similar to those that might be experienced from “natural” radiation.

5.3 RIFE 16 (page 9) also states that: “The data from the programmes will also act as a baseline against which future discharges from any new or existing nuclear power stations can be judged”.

5.4 Recent desk reviews, carried out during production of Previous Consultation Responses related to the Hinkley C proposal, have provided a detailed case study of concerns related to the proposed marine environmental monitoring programmes for the Hinkley C PWR station set out in NNB Genco’s Environmental Monitoring submission (NNB-OSL-REP-000137) and those long established programmes carried out by the UK regulating agencies and reported in the annual RIFE monitoring reports

5.5 Page 4 of the NNB Genco monitoring document submission (NNB-OSL-REP-000137) states that: the programme outlined for Hinkley Point C “is informed by the Environmental Monitoring Programme ongoing for Hinkley Point A and B power stations” and then (page 5) states that, with reference to the atmospheric monitoring at the A and B stations:

“A common strategy for collecting terrestrial samples is to divide areas into an inner zone, which is 1 to 6km from the station and an outer zone, which is 6 to 19km from the station” and argues that “This division helps to distinguish effects that might be due to power station operations from those attributable to external effects (non-site operations).”

5.6 Page 6 of the Monitoring document, still referencing the A and B stations but describing the marine sampling offers no comment on the zonal division, based on distance from the site, for the collection of marine samples. Thus there appear to be no identified inner or outer zones for marine samples.

No comment is given as to why such a policy is considered useful for the terrestrial monitoring programme, but not considered useful for the marine environment.

5.7 Fish and Shellfish monitoring

Para 1.2.2 (page 7) of NNB-OSL-REP-000137 says that fish and shellfish are indicator species because they are foodstuffs and because “they essentially sample the local water and consume other organisms”. This is an imprecise statement that lacks scientific rigour, because it should have been made clear that different fish and shellfish sample different component sections of the local water.

The annual RIFE Reports for the Hinkley site present marine foodstuff sampling and monitoring outcomes in relation to the discharges from the currently operating Hinkley Point A & B NPSs. A review of the marine monitoring at and around Hinkley Point shows that the sample base is by no means extensive. Thus, it is the current practice to monitor only 1 or 2 samples of fish and shellfish (1 cod sample, 1 bass sample, 2 shrimp and 1 limpet samples) taken from just one area (Stolford).

5.8 Additionally, the RIFE reports fail to clarify whether the cod and bass were actually caught at Stolford or whether they were merely landed at Stolford, having been caught elsewhere. Cod and bass are both migratory fish (feeding on less sessile species than some other predatory fish), and the simple fact of their capture does not guarantee that any 1 individual of either species has been in the Hinkley area for any specific time period, nor indicate that they have fed on local prey species. Therefore, the claim that the monitoring of the cod and bass samples “essentially samples” the local water and marine food chain cannot be justified, lacks scientific rigour and is false.

This Submission proposes that sampling of a round fish species such as grey mullet (resident and feeding in estuaries and inshore waters), or demersal flat fish which habitually feed on or close to the seabed on relatively sessile (non-migratory) species, may present more appropriate monitoring species.

5.9 No detail is provided of the number of individuals in each “sample”. There is no evidence that 1 sample of each of 2 pelagic fish species (living and feeding in the water column away from the seabed) represents a legitimate sample base for regional fin fisheries. The general and consensual assumption would be that the larger a sample base can be, the better (more representative), the data outcomes are likely to be.

Such a small sample base offers only a poor data outcome, thus lending more support to the contention that the seafood sampling lacks scientific rigour and provides inaccurate data outcomes.

5.10 It is thus the contention of this Submission that the fin fish sampling and monitoring programme for the existing Hinkley Point A and B stations does not provide a useful or accurate record of the representative radioactivity concentrations to be found in locally caught marine fin fish, hence the dietary dose calculations for locally caught fin fish are flawed.

The same flawed methodologies for sampling and monitoring programmes are proposed for deployment in respect of Hinkley Point C and will similarly fail to provide a useful and accurate record of maximum radioactivity concentrations from the proposed EPR reactors in locally caught finfish.

5.11 The Hinkley Point shellfish monitoring programme reported in the RIFE reports is little better than the fin fish programme. It is based on 2 samples of shrimps and 1 sample of limpets, again from Stolford. No details are provided of the constituents of a “sample” (numbers of individual animals, weight of sample etc)

Since limpets are widely recognised to be both sessile (immobile or at least highly localised) and very commonly distributed, at least it can be assumed that the limpets were indeed harvested at Stolford.

5.12 Limpets are not a significant or popular form of human dietary shellfish, normally favoured only by extreme survivalists, and thus have little relevance as a general seafood dietary indicator species.

Limpets are vegetarians and hence can be said to “essentially sample” the seaweeds at Stolford and to provide some insight into the Stolford seaweed based marine food webs.

However, 1 sample cannot be fully representative of the entirety of the Stolford limpet population, let alone the Hinkley Point regional population. It is therefore the contention of this Submission that that the Hinkley limpet sampling does not provide a useful and accurate data base representative of regional shellfish.

5.13 Shrimp are a popular decapod crustacean human dietary item. 2 samples of shrimps from Stolford are taken for the Hinkley station monitoring programme. It remains unclear whether the shrimp samples were captured at Stolford or were captured elsewhere and landed at Stolford.

Shrimp tend to be relatively sessile, have a small home range and are generally omnivorous. Hence shrimp samples will be representative of conditions at their (very limited home range) place of capture only. Additionally, 2 samples, attributed to 1 specific site (Stolford) fail to be representative of the entirety of potential crustacean/shellfish dietary items likely to be impacted by the Hinkley Point liquid radioactive wastes

5.14 This Submission concludes that the entirety of the fin fish and shellfish sampling and monitoring programme for the existing Hinkley Point A and B stations does not provide a useful or accurate record of the representative radioactivity concentrations to be found in locally caught marine foodstuffs, hence any dietary dose calculations (based on the monitoring outcomes) for locally caught sea foods are flawed and lack scientific rigour.

This Submission concludes that the same flawed methodologies for sampling and monitoring programmes are proposed for deployment in respect of Hinkley Point C and will similarly fail to provide a useful and accurate record of radioactivity concentrations, from the proposed EPR reactors, in locally caught seafoods.

6. Marine Water and Sediment Sampling

6.1 Para 1.2.3 of NNB-OSL-REP-000137 (page 7) correctly reports that radio nuclides can become attached to silt particles and that “the smaller the particle size the greater the surface area and hence the greater adsorption capacity”.

The entirety of the current Hinkley Point marine monitoring activity takes 2 “sediment” samples from each of 9 sites spread across approximately 25 miles of coast between Blue Anchor Bay (about 11.5 miles to the west) and Weston Super Mare about 13.5 miles to the east of the Hinkley Point site.

Thus it is based purely on potential near field/local impacts and discounts the need to monitor further afield despite the evidence set out in earlier and later sections to demonstrate that reconcentration occurs at sites distant from discharges.

6.2 The term “sediment”, as used in oceanography and coastal morphology work, is a very broad term which is loosely refined by the use of the terms cobbles, pebbles, shingle, sand and mud or silt and very precisely defined by use of the Wentworth Scale which defines the “grain size” of sedimentary particles by mms and fractions of mms.

Thus, the finest sediments or “muds” which would be expected to hold the greatest concentrations of Hinkley Point derived marine discharged radioactive wastes, would consist of particles with grain sizes at or below 0.075 mm.

Such material is characteristic of much of the material found in seabed and intertidal deposits in the nearshore zone around the Hinkley site (Bridgwater Bay) and through out much of the Bristol Channel coastal fringe (especially those areas downstream (ie closer to the Severn estuary). The Bristol Channel water column is also characterised by its very high suspended particle content, composed of material in that grain size range.

6.3 However the RIFE reports fail to provide individual descriptions or definitions of the nature of all but one of the sediment sample sets taken. Only 2 individual sediment samples are given a definition other than “sediments” and these are the “Mud” taken from Watchet Harbour (approx 8 miles to the west of Hinkley Point). The remaining 8 sample sets are not given a more precise definition and:

(a)may thus have not consisted of fine grained material;

(b)may not have been subjected to grain size analysis; and

(c)may thus have generated essentially meaningless results because not attached to any useful sediment descriptor.

6.4 Thus it remains unclear:

(a)exactly what type of sediment the RIFE reports have been monitoring at eight of the nine sample sites; and

(b)whether those responsible for taking and monitoring the samples have a record of the sediment types sampled at those other eight sites.

6.5 In addition to their failure to record the precise (grain size) nature of the “sediments” sampled, the RIFE reports fail to provide an extensive suite of highly relevant supporting data as follows:

(a)are the sediment samples taken from the inter-tidal zone or the sub-tidal zone. If taken from the intertidal zone are they taken from the upper, mid or lower sector of that zone?

(b)in which season of the year are the sediment samples gathered (highly relevant to near shore sub-tidal and inter-tidal sediments since seasonal dynamic fluxes exercise strong influences such as accretion/erosion cycles and winnowing and sorting of grain size on such sediments)

(c)what were the ambient weather and sea conditions at the time of sample collection and during the immediately preceding period: this too may exercise strong influences on sediment deposits (as described in b: above) and also because of the potential impact that terrestrial freshwater runoff (rainfall/flood etc) may exercise on both the radioactivity content of the measured samples and also the particle size of the relevant samples.

(d)what were the ambient (high/low: spring/neap) tidal conditions at the time of sample collection and in the immediately preceding period (relevant for the same reasons as b and c above)

(e)whether the same conditions (listed above) were operating at each site, each time the samples were gathered there (in order to maintain coherence across the historical annual results)

Without this supporting data the reported sample radioactivity concentrations are of relatively little relevance and represent little more than a collection of random results with geographical location the only chronological common factor

6.6 The strikingly small sample number base for sediments also militates

against a thorough reportage and understanding of radioactivity concentrations in the Hinkley Point marine environment, because there can be no scientific justification for proposing that 2 samples from annually from each of 9 small sites (across a 25 mile stretch of coast) represent anything other than a very “brief-period” spot sampling exercise.

Certainly such work cannot be claimed to be representative of the entirety of seasonal and annual conditions that will be experienced at those sample sites.

6.7 Thus the strikingly small sample number base and the lack of data and clarity of the sediment monitoring programme plainly militate against a precise understanding of the radioactivity concentrations across the range of “sedimentary” marine and estuarine environment types to be found across the approximately 25 miles of coastline covered by the sediment monitoring programme.

6.8 Noting that the Hinkley monitoring programmes are essentially replicate in principle by those at all other NPS, this Submission concludes that the sampling and monitoring programmes currently undertaken, and proposed for deployment in the case of monitoring future new build NPSs, lack scientific rigour and do not provide the requisite amount, or quality, of data on which to base an understanding of the behaviour and fate of radioactive wastes discharged to sea from the proposed new build Nuclear Power Stations.

This Submission further concludes that the programmes are not appropriate to the task of providing the necessary data inputs to hypothetical models/projections of potential pathways of exposure and dose rates to the public.

7. Other Monitoring Issues

7.1 In addition to the issues raised above in relation to all existing and all New Build sites, there 2 further monitoring issues which are relevant to all sites where the ERP and AP1000 reactors are proposed:

The Developers of stations where both the EPR and the AP1000 reactors may be deployed have both stated that the Environmental Monitoring Programme discussed in their proposal documents will only take account of routine releases from normal plant operation.

7.2 The absence of any discussion of the provision of Emergency Situation Monitoring Programmes (such as that occurring at Fukushima) is a matter of considerable concern since, without some degree of prior planning any emergency response is likely to be constructed and initiated under extreme pressure and without the benefit of rational analysis and discussion or the prior construction of equipment stockpiles.

7.3 Pulsed discharges

Developers of sites where the deployment of UKEPR and AP1000 reactors is proposed have stated that discharges of some radio-nuclides will be intermittent, thus delivering pulsed peaks and troughs of input.

This fact is not addressed in NNB Genco’s Hinkley C Monitoring document NNB-OSL-REP-000137. Thus it may be concluded that there are no plans to construct the proposed marine monitoring programmes for Hinkley C in such a way as to take account of the several implications of pulsed discharges.

Similarly such issues are not referenced in the RIFE reports.

7:4 While of relevance to all nuclides entrained within the proposed pulsed discharges, the issue is particularly important in relation to Tritium because

(a)Tritium is specifically indicated as one of the radio nuclides intended for pulsed discharge

(b)Tritium has a short life and hence peak concentrations in environmental samples (following pulsed discharges) may not be recorded by the proposed very low number/low frequency monitoring programmes based on those already in existence

(c)Tritium is shown to very rapidly incorporate into marine samples (including foodstuffs) and thus the proposed low frequency/low number sampling programme will not be geared towards capturing peak tritium concentrations in foodstuffs.

(d)thus, due to a: and b: (above) marine food pathway doses to exposed critical populations will not be effectively and accurately calculated each year, nor on a year on year chronological basis.

8. Where should the programmes monitor?

8.1 Page 11 of NNB-OSL-REP-000137 explains that the geographical locations at which samples and radiation dose rate measurements are taken is an important part of the Environmental Monitoring programme and offers explanations for, and guidance on, the choice of sampling and monitoring sites in relation to NPS.

It is specifically stated that the programme “must provide representative data about the levels of radioactivity in the local area and ensure that locations where higher results might be found are sampled.”

8.2 The principle of providing representative data has been alluded too above in the context of sediments and sedimentology where it was explained how the principle is not adhered to by the current monitoring programmes.

8.3 NNB-OSL-REP-000137 states (page 10) that fine grained sediments “accumulate particle reactive nuclides present in the water”.

This Submission has already explained, and provided examples of, how this mechanism leads to re-concentration of various nuclides in the sediments (with higher levels in fine sediments) when compared to concentrations in ambient seawater.

This has been widely demonstrated in many studies, including the RIFE reports, and is a particularly significant factor in the relatively high concentrations (compared to ambient seawater) of alpha emitters and actinides found in sediment deposits in UK waters.

8.4 In the context of sediment accumulation of nuclides, it is evident that the optimum methodology for thoroughly examining the outcomes and extent of this particular parameter is to base the identification of sample sites on a thorough understanding of the grain size of the coastal and estuarine sediments in the vicinity of NPS. This can best be done if it is based on studies utilising Wentworth Scale grain size analyses (see above).

Only then can “representative data about the levels of radioactivity in the area” and “locations where higher levels might be found” be accurately gathered.

8.5 The statement that the programme “must provide representative data about the levels of radioactivity in the local area and ensure that locations where higher results might be found are sampled.” is contradicted by NNB Genco’s other statement that “The locations should be evenly located around the station and be at appropriate distances” (Page 11 of NNB-OSL-REP-000137).

8.6 The two statements are mutually exclusive, since there is absolutely no evidence that there has been any grain size analysis work, nor any other scientific work, to justify an assumption that “evenly located” and “at appropriate distances” sample sites provide an accurate (or even approximate) representation of “representative” or “higher results”.

8.7 In fact, without grain size analysis, marine, coastal and estuarine sample site choice is an essentially hit or miss operation not based on scientific rigour and incapable of providing the required “representative data about the levels of radioactivity in the area” and “locations where higher levels might be found”

NNB-OSL-REP-000137 (page 12) proposes that the sampling locations used for the current Hinkley A and B stations monitoring are relevant to the proposed Hinkley C monitoring programme. In the context of the findings above, it is evident that the proposed Hinkley C monitoring will be as inappropriate and irrelevant as the current programme is for the A & B stations.

8.8 NNB Genco’s proposed sediment monitoring programme in relation to the proposed Hinkley C liquid discharges (based on current Hinkley A and B monitoring programmes) is strictly restricted to near field observations (maximum of about 13 miles from the site).

Thus, an extensive area of “down stream” Somerset coast, including relatively populated and popular coastal areas between the eastern extent of Hinkley sampling (Weston Super Mare) and the Oldbury discharge point, remains un-sampled and un-monitored for radioactivity from the Hinkley Point site.

8.9 In addition, virtually all the South Wales coast (again densely populated and popular with visitors) also remains un-sampled and unmonitored (other than the relatively small area around Cardiff where sampling is undertaken specifically to detect the impact of medical diagnostics factories operating in Cardiff).

8.10 This is particularly relevant and significant in the case of the extensive inter-tidal fine sediment deposits of:

(a)the Avon Estuary;

(b)the estuaries of the south Wales rivers;

(c)the extensive inter-tidal mud flats fringing the Severn coast of Gwent and Glamorgan; and

(d)the extensive fine sediment deposits of Swansea Bay and Carmarthen Bay.

Where sediment associating radio-nuclides (especially the long-lived alpha emitters/actinides) may have already begun to appear as a result of the current and historical discharges of the existing Hinkley and Oldbury reactors and may further concentrate if the proposed Hinkley C and Oldbury B stations begin discharges of liquid radioactive wastes.

8.11 Similarly, the surface waters, which have travelled past, and received the radioactive waste discharges of, the Hinkley and Oldbury sites, may also be of radiological significance.

It can be seen that the NNB GENCO statement is merely an echo of the policy/strategy carried out by the UK Regulating Agencies responsible for the production of the annual RIFE reports, itself based on the original flawed hypothesis for the behaviour and fate of sea discharged radioactivity.

8.12 This Submission concludes that, in the context of the lack of such monitoring in such areas it is legitimate to state that there is a wide swathe of ignorance concerning the radiological impact that the exiting stations may be making on those areas.

It is thus imperative that, at the very least, a wide ranging and detailed baseline survey of radioactivity in the South Wales and Avon sedimentary and water column environments be carried out prior to the initiation of discharges of radioactive waste from the proposed new reactors.

8.13 Similarly it is imperative that an ongoing sampling/monitoring programme should be maintained in order to investigate and quantify any ongoing effects of those proposed new discharges of radioactive wastes in far field environments such as those of the south Wales coast.

9. Data Gaps and “unknowns”

9.1 From the detailed desk research which underpins the Previous Consultation Response it has become apparent that there are a number of highly relevant scientific issues where there are a wide range of “unknowns” across a wide range of technical fields. Some examples are discussed below.

9.2 Marine hydrodynamics

From the tone of both the nuclear new build developers proposals to discharge radioactive wastes into UK coastal waters and the regulatory agencies reporting of marine monitoring, it might be assumed that all of the relevant marine scientific parameters likely to govern, drive and influence the behaviour and fate of radioactive wastes discharged to sea are fully understood.

However, this is very far from the case and there are, in fact, many important areas where marine scientists are at pains to point out that the science is poorly understood and that much research is needed before a full understanding is gained

9.3 Mapping of UK seas and marine hydrodynamics remains a still un-completed project. The most recent publication of such research created by a relevant UK Ministerial Department was the 1981 MAFF “Atlas of the Seas around the British Isles” which, when addressing the issue of water body movements (upper half of the water column) constantly reminds the reader of

(a)“the lack of systematic, long term data collection in almost all areas”(for the English Channel and the North Sea); and

(b)for the Irish Sea says “It would appear that more often than not there is a south to north flow to the west of the Isle of Man but the circulation shown for the region to the east of the island is still a matter for argument”.

NB these statements were made nearly thirty years after the commencement of discharges from Sellafield.

(Ref 13)

9.4 Tracer study research in the Bristol Channel, using marked fine sediments, have indicated that most of the fine sediment transport occurs within the Bristol Channel turbid (high sediment load) water mass and propose that the most significant sinks (areas of deposition of fine sediments) are probably

(a)Bridgwater Bay (the receiving area for the Hinkley liquid radioactive waste discharges)

(b)the peripheral areas of the Parrett and Avon estuaries (Somerset and Avon coasts)

(c)the Wye and Usk estuaries and their associated salt marshes (south east coast of Wales)

(d)and a few offshore sites such as the Newport Deep and Nash Passage (off the welsh coast)

(Ref 14 )

NB: In this context it is important to remember that pollutants associate strongly (by adsorbtion) with fine sediments. This evidence highlights the importance of the lack of radiological monitoring for these substances (as highlighted in preceding paragraphs).

9.5 In the case of the Bristol Channel marine environment, designated to receive discharges of liquid radioactive wastes from the proposed Hinkley C reactors, a 2010, in depth review, presented in the peer reviewed Marine Pollution Bulletin highlighted a number of highly significant unknowns regarding crucially important aspects of marine environmental science relevant to the behaviour and fate of pollutant wastes discharged into that specific sea area. (Ref 15)

9.6 The Marine Pollution Bulletin review concluded that the strength of currents and their distribution are, ultimately, the principal drivers determining long term sediment transport, deposition and erosion (either in suspension or as bed load) in the Bristol Channel/Severn Estuary system and that the “hydrodynamics also directly influence (and perhaps dominate) the dispersion of discharges”.

9.6 The review also stated that: “a better understanding of these features and their linkages would improve management options for the system”.

9.7 Noting that flocculation (aggregation of fine particles) “is a principal mechanism which controls how fine sediments, and thus contaminants, are transported”,

the review reported that

“the interpretation of the significance of this process is only just beginning to emerge.”

(Ref 15)

9.8 The Marine Pollution Bulletin review further noted that, with respect to understandings of the sediment dynamics and physical processes, much of the research and data collection was undertaken several decades ago and now there is a requirement to:

(a)investigate how flocculation of suspended sediments responds to different degrees of turbulent mixing;

(b)develop better sediment transport models to quantify settling of flocs, erodability of bed sediments and the settling of sediments during different tidal conditions;

(c)examine how the mineralogical composition of muddy sediments influences their capability to both flocculate and adsorb/release pollutants;

(d)Map the extent and magnitude of salinity intrusions and the turbidity maximal, including depth profile measurements in order to provide representative distributions of both suspended sedimentary matter and salinity on seasonal and neap/spring tidal cycles and time scales;

(e)to determine the extent to which biological processes affect the behaviour of sediments and the bio availability of sediment associated contaminants

(Ref 16).

9.9 In the context of the statements set out in the preceding paragraphs, this submission concludes that there is, at the least, a 5 clause degree of UN-certainty about the behaviour and fate of radioactive wastes discharged into the Bristol Channel marine environment from both the existing NP stations and the proposed new build NP stations.

9.10 This submission reiterates the fact that the most recent authoritative description of UK wide marine environmental parameters (the MAFF Atlas) is very careful to point out the lack of data and the wide range of uncertainties about such parameters.

9.11 This submission draws attention to the fact that

(a)neither NPS new build developers NOR UK government regulatory agencies have referenced these scientific and technical uncertainties; and that

(b)they have both preceded with applications and GDA as if there were no such uncertainties and all those marine environmental parameters relevant to the behaviour and fate of sea discharged radioactive wastes were fully marshalled and understood.

Accordingly this Submission concludes that neither developers nor regulators have proceeded with appropriate diligence and scientific rigour.

10. Unknown//un-Quantified Discharges of Alpha Emitters/Actinides

10.1 Developers proposing construction of NPS using both the UKEPR and the AP1000 reactors report their intention to discharge liquid fission and activation products. Among these products are various actinides and alpha emitters produced by the irradiation of “tramp” uranium contamination of the outer surfaces of fuel pins, or of uranium leaking from inside the fuel pins.

10.2 Developers have provided only minimal detail on the constituent components of the actinides and alpha emitters to be discharged. EDF, the manufacturers of the UKEPR, and NNB Genco the developers of NPS proposing to deploy those reactors have not provided full details of the alpha/actinide wastes to be discharged in their liquid waste streams.

10.3 However, Westinghouse, the manufacturers of the AP1000 reactor, have provided a Table detailing the constituent components of their proposed liquid radioactive waste discharge streams.

The Table lists 12 individual actinide/alpha emitters : 5 isotopes of Plutonium, 3 isotopes of Uranium, 2 isotopes of Americium, and 2 isotopes of Curium as components of the “expected annual radioactive effluent discharges”.

(Ref 18)

10.4 An (unreferenced) 1989 Table entitled “Assumed Isotopic Composition of Annual Liquid Discharges from the Hinkley Point C”: issued by the CEGB (to the 1989 Hinkley C PWR Inquiry) in relation to the proposed fleet of PWRs similar to that at Sizewell, lists 17 actinides including 6 isotopes of Plutonium, 5 of Americium, 3 of Curium, 2 of Uranium and 1 of Neptunium.

(copies available from this consultant)

10.5 NNB Genco state that “alpha activity is not presented as a significant group of radio nuclides for GDA, and measurements carried out at PWR units do, in fact, confirm that discharges are always below detection limits” (Ref 17).

NB Previous Consultation Responses previously have sought a clarifying definition of these “detection limits” from the regulatory GDA and to date have not been provided with one.

10.6 Similarly, but with one exception, the Westinghouse document (Ref 18) also refrains from offering quantification of their listed alpha/actinide discharges from the AP1000 reactor, but (unlike the EDF/NNB Genco documentation) they do state that the discharges of the 12 individual listed isotopes are expected to be “negligible” and they define “negligible” as “less than 3.7E + 4 Bq” (less than 37,000Bq per year).

(The AP1000 NPS will have three reactors, thus the aggregated “negligibility” will be 110,000 Bq per year.)

10.7 The Westinghouse document does not provided a scientific or technical justification for defining 37,000 Bq per year of alpha/actinides as negligible, nor does it clarify if this turn of phrase refers to each individual isotope or to the aggregated yield of the 11 isotopes.

10.8 The Westinghouse exception is for Plutonium 241, which is described as “significant” because it has a long half-life and may persist and/or accumulate in the environment.

This Submission assumes that the “significance” of the Pu 241 is also derived from the fact that Westinghouse predict that that the annual average discharge to sea from an AP1000 reactor is expected to be 80,000Bqs per year, with an expected annual maximum of 108,000Bqs per year.

(For a triple AP1000 reactor NPS this will be average discharges of 240,000 Bqs per year of Pu 241, with a predicted maximum of 324,000 Bqs per year)

10.9 No such detail is provided for the UK EPR reactors in relation to Pu 241 discharges.

However, given that both Westinghouse and NNB Genco documentation make “guideline” reference to operational experience and data from other existing PWRs when discussing reactor radioactive waste arisings and discharges of liquid radioactive wastes to sea, this submission assumes that it may be the case that arisings and discharges are likely to be (loosely) similar in volume/quantity when plant capacities are similar.

10.10 On that basis, in the context that three AP1000 reactors are (broadly or loosely) comparable in terms of energy production to 2 UK EPR reactors, and in the complete absence of any relevant data from the manufacturers and developers of the UK EPR, this Submission postulates that proposed 2 UK EPR reactor stations MAY have similar alpha/actinide outputs to those of the 3 AP1000 reactor stations:

ie yearly average of 240,000 Bqs of Pu 241, yearly maximum of 324,000 Bqs

10.11 If this should be the case, this Submission does not concur with any suggestion that UK EPR station Pu 241 discharges are negligible and, on the contrary, argues that both NNB Genco and the Regulating Agencies and the GDA process should have clarified and quantified the issue of Pu 241 discharges from the UK EPR reactors.

10.12 This Submission further wishes to draw attention to the fact that the principal reason given by Westinghouse for the identification of Pu 241 as an isotope of “significance” (because it has a long half life and may persist or accumulate in the environment) applies equally well (if not more so) to the other alpha/actinide fission products in the proposed discharge streams from both UKEPR and AP1000 reactors.

10:12 In fact, Pu 241 has a relatively short half life of 14.4 years and is thus relatively non persistent compared to other isotopes listed (above) in the alpha/actinide discharges. For instance, the decay/daughter product of Pu 241, Americium 241, has a half life of 432.2 years which of course makes it far more persistent in the environment than Pu 241.

The majority of the other “listed” alpha/actinides similarly have half lives ranging from hundreds through to thousands to millions of years (in the case of Neptunium).

10.13 This Submission draws attention to the fact that the Regulating Agencies, through the GDA process, appear to concur with the proposal that alpha/actinide discharges are not important, because the GDA process does not appear to have demanded clarification of the issues raised above, nor has it demanded any limits on alpha/actinide discharges other than those of Pu 241.

10.14 The issue of the listed alpha/actinides is one of considerable significance because alpha activity is generally considered to be of major (potential) radiological health significance, because if ingested or inhaled such material may cause more significant and lasting damage to human health than other forms of radioactivity.

10:15 In this context further urgency is given to the understanding and control of alpha active radioactive wastes by the fact that, in UK marine environments there appear to be a range of mechanisms of increasing concentration in addition to those discussed in Section 4 above.

10.15 Thus, although the annual RIFE monitoring reports (any year) do not bother to record concentrations of Pu 241 in the marine environment around (for example) Hinkley Point, they do undertake monitoring for 3 other Pu isotopes as well as Americium 241 and 3 isotopes of Curium.

NB This Submission draws attention to the apparent dichotomy between

(a)the developers/manufacturers characterisation of these isotopes as of “negligible” significance and the regulating Agency’s apparent decision to concur with this position;

compared to

(b)the developers/manufacturers characterisation of PU 241 as “significant” and the Regulating Agency’s and monitoring body’s decision to NOT MONITOR for this isotope.

10.16 The RIFE Reports (nos 6, 13 & 15 etc) record positive (but rising!) low concentration results for several isotopes of Plutonium and one isotope of Americium in Hinkley Point C samples (shrimps only):

Hinkley 2000
Sample	Pu238	Pu239/240	Am241	Cm242	Cm243/244
Shrimp	0.000073	0.00034	0.00067	NA	NA

Hinkley 2007
Sample	Pu238	Pu239/240	Am241	Cm242	Cm243/244
Shrimp	0.000063	0.00048	0.0016	NA	NA

Hinkley 2009
Sample	Pu238	Pu239/204	Am241	Cm242	Cm243/244
Shrimp	0.00021	0.00091	0.00076	0.00011	NA

(Similar monitoring at the Sizewell B site also reports a positive presence for 2 isotopes of Plutonium, Americium 241, and isotopes of Curium.)

10.17 Neither the manufacturers of the UK EPR and the AP1000 reactors, nor the developers of proposed nuclear new build, nor the regulating agencies (during the GDA process) have addressed the issue of the established presence and rising concentrations of Pu, Am and Cm in the context of the proposals to discharge further unquantified volumes of these products. Apart from commenting that the concentrations of these isotopes in seafoods is of “negligible significance” the RIFE reports have not addressed the issue of rising concentrations or offered an explanation for the observed phenomenon.

10.18 This Submission concludes that, in the context of the information set out in the preceding paragraphs, there are significant issues relating to the discharge to sea of alpha/actinide wastes from proposed nuclear new build which have not been examined during the GDA process.

Thus the potential environmental and public health impacts of the discharges of Pu, Am and Cm are unknown and unquantified and therefore any conclusions reached by the GDA process must lack scientific rigour in relation to those issues.

11. Issues Arising From the Decay Production of Americium 241

11.1 During the late 1980s it was realised that there was an issue of rising marine environmental concentrations of alpha emitting Americium 241 derived from the decay of historically discharged (in virtually unlimited quantities till relatively recently) Plutonium 241.

It has been projected that by the end of this century, that the marine Americium 241 production from the decay of previously discharged Pu 241 will be delivering approximately 1,300 curies (48 Tbq) per year into Irish Sea (and associated marine area) environments.

(Ref 19)

NB RIFE 16 (2011) reports that in 2010 the Sellafield recorded discharges of Americium 241( + Curium) was 1.66E+07 Bq

11.2 The annual RIFE reports confirm, and make regular reference to, this issue (in relation to marine sediments).

However, neither the reactor manufacturers, new build developers nor the regulating agencies (via GDA) discuss the phenomenon in relation to the proposed ongoing discharge of Pu 241 (which generates decay production of Am 241), nor have they discussed the issue in relation to the direct discharge of unquantified volumes of Am 241 (see section 10 above).

11.3 This Submission draws attention to the wide consensus that

(a)Americium 241 is a known alpha emitter and potentially at least as radio toxic as the Plutoniums (if not more so);

and that the fact that

(b)like the other alpha/actinides, decay product Americium 241 will eventually appear in coastal and estuarine fine sediment deposits.

11.4 This Submission concludes that, in the context of the information set out in the preceding paragraphs, there are significant issues relating to the discharge to sea of both Pu 241 and Am 241 from proposed nuclear new build which have not been examined during the GDA process.

Thus the potential environmental and public health impacts of the discharges of Pu 241 and Am 241 (in conjunction with the decay product Am 241 arisings) are unknown and unquantified and therefore any conclusions reached by the GDA process must lack scientific rigour in relation to the environmental and public health significance of Pu 241 and Am 241.

12. Studies of Sea to land Transfer of Marine Radioactivity (Sea Spray and Marine Aerosol Pathway

12.1.1 Since the early 1980s a small number of studies have been carried out on the sea to land transfer of radioactivity via sea spray and marine aerosols. The initial work was carried forward by the research division of the UK AERE, who chose the Irish Sea as their field of work (because of the presence of Sellafield and its major programme of discharge to sea of liquid radioactive wastes) and various nuclides of Plutonium (Pu) and Americium (Am) which became the radio nuclides of interest.

12.2 The AERE studies reported that:

(a)several nuclides of Pu and one of Am were found to be airborne in any coastal area where the field work was carried out in onshore wind conditions and that the magnitude of the effect generally increased with wind speed;

(b)the magnitude of the effect was also very closely linked to the volume of fine sediment particles ejected into the air in spray or aerosol formations and subsequently captured on muslin screens; but

(c)that the work was unable to provide accurate data on the true extent of the sea to land transfer of actinides, because the attempts to quantify the phenomenon were based on the use of flawed technology and methodology, which was itself derived from the absolute non-availability of appropriate equipment.

12.3 Muslin screens were deployed for the capture of airborne particles at surf line and near coastal (terrestrial) environments, while high volume air samplers (which draw air through an opening 1 metre above ground level) were sited inland of the muslin screens.

Muslin screens were originally deployed as a back up to the use of high volume air samplers, which were noted to be “not particularly suited” to sea to land transfer studies because they are “believed to be not very efficient for the relatively large particles”. (Ref 20 )

12.4 However it was reported that muslin screens provided inherently inaccurate data because as wind speeds increase (especially beyond Force 5) the muslin stretches and its porosity increases allowing more and more (and larger and larger) particles to pass through the material.

Attempts to estimate collection efficiency of the screens were unable to provide a definitive efficiency level for low winds but concluded that, at wind speeds of 12 metres per second (28 to 30 mph), the transmission/porosity of the screen was noted to be as high as 50% (efficiency had decreased by 50% of whatever it would be at minimum wind speeds).

It was accordingly noted that muslin screens should be used “only as a qualitative tool to compare relative concentrations of actinides in sea spray” (Ref 21)

12.5 It was also reported that the muslin screens (5 m long, 1 metre deep) were mounted vertically with their lower edges 1 metre off the ground level, but that the “enriched spray front” detected by the UKAEA at the shoreline in force five winds was probably about 10 metres high.

N.B. At greater wind speeds it seems highly likely that an “enriched spray front” will be higher and that the transmission/porosity failure of the screens will become even greater than that observed at 12 metres per second wind speeds

12.6 Despite the inability to provide usefully quantitative data on the concentrations of the actinides Pu and Am transferring from the marine to the terrestrial environments, such studies have conclusively demonstrated that the phenomenon does occur.

12.7 Subsequently further studies attempted to investigate and confirm the impacts of the phenomenon on terrestrial environments. In order to ascertain the significance of sea to land transfer of radioactivity along the Cumbrian coast, soil samples along two transects extending up to 20km inland were analysed for the insoluble nuclides Plutonium and Americium in 1982

It was reported that: “Pu and Am deposits decrease with distance inland and correlate with deposits of marine-derived sodium. An enrichment of actinides in sea spray relative to seawater is required to account for the observed deposit.” (Ref 22)

12.8 As mentioned above, the study of the sea to land transfer of anthropogenic marine radioactivity commissioned by the nuclear industry and/or government agencies has been focussed:

(a)on the coastal areas of the northern basin of the Irish Sea in the vicinity of the Sellafield sea discharge point sources; and

(b)on the insoluble alpha actinides/transuranics.

However there is a body of independently commissioned and conducted work, which has reported on the phenomenon in other coastal areas and in respect of “soluble” radionuclides, some examples follow:

12.9 In south west Wales, Dyfed County Council commissioned a study of radioactivity in the county in the late 1980s, which, among other issues, was asked to confirm or deny the presence of indications of sea to land transfer of Sellafield derived sea discharged material in inland terrestrial environments.

This study confirmed the presence of Caesium 137 (proved to have been derived from Sellafield sea discharges) in pasture grass at 10 km inland of the Cardigan Bay coast of south west Wales, thus confirming:

(a)an unexpectedly deep inland penetration of this isotope;

(b)the fact that it must therefore be entering into the regional terrestrial dairy and meat food chain; and

(c)and strongly implying it’s entry into other local produce food chains (potatoes, vegetables and fruit etc) (Ref 23).

12.10 In a study of patients from North Uist (Western Isles of Scotland) an independent medical team found excess Caesium body burdens compared to those in patients from the Scottish mainland and investigated the source of Cs in the N.Uist patients.

The immediate dose source was shown to be excess dietary intake of Cs, which was identified in all types of island grown food produce and environmental samples. Island dairy produce, meat and fish all had higher Cs concentrations than their mainland counterparts, however it was noted that fish was not a significant part of average islander diet.. High concentrations of Cs were also reported for N.Uist seaweed, beach sand, inland peat and both coastal and inland pasture grass.

Highest body burdens of Cs (and highest concentrations in urine samples) were found in those patients shown to be consuming the greatest dietary percentage of island produce. The average islander dietary dose, from Cs 137 alone, was calculated at 13.7 micro Sv.

NB: In the context of this section of the Submission, it is highly relevant to compare

(a)the average Uist, single nuclide, local terrestrial dietary dose (13.7 micro Sv), to

(b)the 7 nuclide dietary dose received by residents of Hinkley Point eating locally produced terrestrial foods (14.2 micro Sv)

[Addendum 1 MAFF 5. Topic 2. Hinkley C PWR Inquiry Documents 1989. Duplicate Diet Studies. 3 pages]

The “fingerprint” of the analysed Cs indicated a clear Sellafield sea discharge component in the majority of samples. The study concluded that it was “important to note that an isotope discharged into the sea as waste may return to land at considerable distance from the site of discharge and enter the human food chain”.

(Ref 24)

12.11 Since North Uist is shown to be saturated with Sellafield sea discharged Cs, it is not unreasonable to assume that other nuclides known to transfer from the sea to the land are also present in the islanders diet. Islander doses for total nuclides will plainly be significantly greater than the calculated dose for CS only.

NB:North Uist is approximately 200 kms by sea from the Sellafield discharge pipe.

12.12 In addition to the sea to land transfer by pathways of sea spray and marine aerosols, inundation during storm surges and tsunami type phenomena is also a recognised, though poorly studied pathway. (see section 4 above which discusses Enrichment Factors)

Section 4 above also referenced the fact that Plutonium Enrichment Factors of 26,000 (relative to those in ambient sea water) have been recorded in marine algal blooms.

The transfer of marine fine particles, re-suspended from the drying surfaces of exposed inter-tidal sediments, during periods of onshore wind has also been alluded to in some studies but is very poorly researched.

12.13 There may be also be possibility that other pathways such as fog formation and evaporation from enriched sea surfaces and the drying out of inter tidal sediments may also make a contribution to sea to land transfer, such processes may be particularly relevant in the case of soluble nuclides such as Caesium and Tritium but such pathways remain hypothetical at the present as no studies appear to have investigated such a possibility.

13. Flaws and Failures of Sea to Land Transfer Reporting

13.1 In the case of the UK Nuclear industry, reactor manufacturers, nuclear new build developers and the regulating authorities, there does not appear to be

(a)a coherent policy towards,

(b)a coherent understanding of, or

(c)a coherent reporting of the real facts of the issue of sea to land transfer of anthropogenic radioactive wastes derived from the sea discharges of nuclear sites.

13.2 The AERE study (published in 1982) and referenced above, concluded that the inhalation (lung) dose to the public from Pu 239 and Pu 240 ( 2 nuclides only) was about 1% of the ICRP 5mSv annual effective dose equivalent then in operation.

However it is important to note that the study had measured the presence of a total of only 5 sea to land transferring nuclides on the measuring devices (Caesium 137, Plutonium 238, Pu 239, Plutonium 240 and Americium 241) and that there are has never been any evidence to suggest that ONLY THOSE 5 are actively transferring from the sea to the land via atmospheric pathways.

Thus the reported dose to the public was based on only a partial record (2 out of the 5 nuclides measured for: and possibly many more which were not measured for) of the full potential range of nuclides which would have contributed to dose.

13.3 This Submission draws attention to the fact that many other nuclides are present in the proposed radioactive waste discharges to sea from proposed new build AP1000 and UK EPR reactors. One table issued by Westinghouse, the manufacturers of the AP1000 reactor lists a total of 65 nuclides described as “expected annual release of radioactive effluent discharges”(Ref 18) consisting of either insoluble or soluble radionuclides.

No evidence has been presented to prove that ONLY the 5 radionuclides measured for in the AERE studies are available for suspension in marine aerosols and seasprays.

Therefore this Submission concludes that it is inevitable that inhalation of such aerosols and seasprays MUST be delivering doses from many more radionuclides than those 2 factored into the already flawed dose estimates.

13.4 In 1990, page 29 of the MAFF (annual) Aquatic Environment Monitoring Report (Number 23) under the heading of “External Exposure”: stated that “the levels of radio nuclides in (marine) sediments give rise to only very minor radiation exposures to the public following inhalation of resuspended particulates including those from the surf line”.

In justification of the statement, the MAFF AEMR referenced an even earlier 1981 study (Ref 26) in which the dose is reported to be 0.2% of the derived air concentration (DAC) modified for members of the public.

13.5 It is highly relevant to note that both of the above mentioned research studies were carried out at a very early stage in the investigations of sea to land transfer and were using data gathered by the use of the inefficient and inaccurate tools which had been specifically described as NOT SUITABLE FOR QUANTIFICATION WORK.

13.6 It is also of the utmost relevance to note that

(a)The dose calculations undertaken for the 1981 and 1982 studies were based on 1979 ICRP values when the annual effective dose equivalent limit was 5mSv.

(b)In 1986 the ICRP limit was reduced to 1mSv.

(c)1987 the UK NRPB had given “interim guidance” that limit should be reduced to 0.5 mSv per year

13.7 This Submission draws attention to the fact that the MAFF AEMR No 23 had uncritically and mistakenly carried forward a series of errors and lapses in information to the public in that the calculated doses were

(a)based on the effect of only two (of potentially many) nuclides;

(b)based on calculations derived from the use of inefficient and inappropriate equipment specifically described as NOT SUITABLE FOR QUANTIFICATION WORK; and

(c)based on historical dose rate limits which were both outdated and a factor of 10 times higher than the contemporary “guidance” dose rate limit (NRPB 1987) and five times higher than the eventual agreed level of 1mSv.

This catalogue of specific inaccuracies about dose rates by inhalation via the marine seaspray/aerosol pathway were repeated in subsequent MAFF AEMR reports through to 1993 and have subsequently been promulgated by nuclear industry and regulatory agencies alike as “fact” thus enabling those bodies to jettison and disregard any further concern in that specific pathway..

13.8 By 2000, the issue of resuspended particulates in sea spray from the surf zone had been dropped from Reports and replaced by a discussion of “resuspended beach sediments” which are a radically different issue.

13.9 From a Marine Science perspective, resuspended particulates in sea spray and marine aerosols must, by definition, be relatively small and “fine” enough to be suspended in the water column. The opposite may be true of “beach sediments” because

(a)“beach” is not equivalent to mud flat or salt marsh environment where fine sediments deposit out;

(b)“beach sediments” are those found deposited out on beaches and may well be of larger particle size range than “suspended sediments” in water columns;

(c)beach sediments are not necessarily involved in sea spray/marine aerosol transport from sea to air to land; and

(d)resuspended beach sediments may well be those involved in dune building processes (transported by wind across a dry/or drying intertidal: and by virtue of their weight not generally reaching a great height above ground).

13.10 Thus Radioactivity in Food and the Environment (RIFE-5:pub’ 2000) page 40, under the heading “External exposure”, makes no mention of inhalation of resuspended particulates including those from the surf line but does report that “inhalation of resuspended beach sediments and inadvertent ingestion of the same material give rise to only minor radiation exposures to the public” and references an NRPB study published in 1994 as the source for the statement.

(Ref 34)

13.11 However a review of the 1994 NRPB study reveals the following

(a)the study began in 1987 and finished prior to the publication date

(b)the study is a desk review of field and modelling work completed before the commencement date

(c)all dose calculations were based on the dosimetry set out in ICRP Publication 26 (published in 1977)

(d)the study did not investigate the impacts of marine aerosol/seaspray as this had previously been concluded insignificant.

(e)the NRPB study was flawed because it carried forward, repeated and compounded all of the errors set out in paras 13:1 to 13:7 above with regard to investigating a very limited group of nuclides and making use of outmoded and redundant ICRP dosimetry.

13.12 Subsequently (and still with a close focus on the Sellafield coast), there have been ongoing investigations of aspects of sea to land transfer in and around the Ravenglass Estuary. These have latterly focussed on the analysis of terrestrial foodstuffs to investigate the extent of transfer of radio nuclides from sea to land. Analysis of samples of milk, crops, fruit, livestock and other environmental indicators are collected annually and analysed for radio nuclides released in liquid effluent discharges from the Sellafield pipelines. The general drift of this work is to attribute the transfer to inundation from the sea, deposition from seaspray and aerosols and the use of seaweeds as a fertiliser.

13.13 Thus the annual RIFE reports regularly report the detection of low levels of Technetium 99 and other artificial nuclides and also identification of (probably Sellafield derived) transuranic nuclides such as Pu 238, Pu 239 and Pu 240 in samples + technetium: thus confirming the occurrence of sea to land transfer and the entry of sea-discharged radioactivity into both wild and cultivated human terrestrial food chains. (Ref 35)

13.14 From the evidence set out above this Submission concludes that the understanding of the mechanisms of sea to land transfer are poorly understood and measured, because, as of yet there is no indication that technologies suitable for the QUANTIFICATION of sea to land transfer of radionuclides in marine aerosols and seaspray are available or have been deployed.

13.15 From the evidence set out above, this Submission concludes that attempts to calculate potential doses to the public via inhalation of marine aerosols and seaspray containing

(a)suspended particles and their adsorbed non soluble radionuclides; and

(b)seaspray/aerosol marine water containing dissolved soluble radionuclides (Caesium/Tritium etc).

Remain deeply flawed and highly inaccurate and lacking in scientific rigour and thus do not provide any accurate or useful data.

This Submission concludes that the converse is true and that the data that has been promulgated is deeply flawed and provides a false and misleading representation of the doses to the public via these pathways.

14. Unavailable Information on the issue of Sea to Land Transfer of radioactive wastes

14.1 There has been, and continues to be, a major problem due to the lack of accessible historical data. One of the major problems has

(a)the relative paucity of relevant work; coupled with

(b)the almost single minded focus on researching sea to land transfer issues in the north eastern basis of the Irish Sea (ie that area to the east of the Isle of Man).

Other than the body of work in that sea area, very little has been conducted elsewhere. Despite a data search I have only found reference to 1 other study in UK waters at Carlingford Lough (Ireland).

The fact that research is focussed on the N.E. basin of the Irish Sea presumably relates to the presence there of the Sellafield site and the fact that its sea discharges represent by far the largest volume of radioactive waste inputs to a UK sea area.

14.2 However, this Submission draws attention to the fact that the sea is not a single uniform entity and that even within one sea area there will be wide range of variations in the environmental parameters (sediment loading, current speeds, freshwater inputs, water temperatures, wind exposure and fetch etc).

Across several discrete sea areas these variations are likely to be even greater. Thus Bristol Channel environmental parameters will differ widely from those found in the southern North Seas and neither may be similar to those found in the north east basin of the Irish Sea.

In the context of the evidence sited above, this Submission warns that the Nuclear Industry/Government Agency focus on N.E Irish Sea research on sea to land transfer means that there exists a body of unknown “data gaps” about both the behaviour and fate of radioactive wastes discharged to sea and sea to land transfer mechanisms and impacts in sea areas other than the N.E. basin of the Irish Sea.

14.3 In the case of the UK work, while some information is available from peer reviewed journals, some data produced by government agencies and nuclear industry bodies can rapidly disappear from public access.

14.4 The most recent example encountered by this consultant has been the attempt to access a copy of one of the most recent UK Government/Regulating Agency reviews of Sea to Land Transfer issues:

“Sea to land transfer of radio nuclides. How much do we know?” Ould-Dada, Z. 2000. (Proceedings 2nd Radrem-Tesc Workshop. London: Jan 21.1999. DETR/RADREM/00.001 DETR London) which has been much referenced in recent annual RIFE reports and other documents, in support of the arguement that sea to land transfer is of low radiological and public health significance.

14.5 Surprisingly however, applications for a copy of this paper, made to the libraries of DETR, CEFAS, DEFRA, DECC and even to the author himself (now working for the DECC) have been met with the reply that it is no longer available. No other explanation has been offered for the inability to produce a copy of this paper.

Thus it is not possible to carry out an analytical review of this, or similar, papers. Given the title of the Ould-Dada paper it is proposed that it would have some close relevance to issues under discussion here.

This Submission draws attention to the fact that during the research work carried out during production of Previous Consultation Responses, none of the documents (originating from developers or regulatory agencies) studied by this consultant made any reference to the Ould-Dad paper and thus it is concluded that they too are not aware of its contents or its implications.

15. Fate and Behaviour of Tritium in Marine Environments.

15.1 Historical understanding of the significance of fate and behaviour of tritium

Historically there has been a wide consensus between the nuclear industry and the regulatory agencies that Tritium was of little radio biological significance, largely based on the assumption that discharged tritium (as tritiated water) would naturally dissolve to infinity once in the marine environment and thus present no radio biological hazard. This attitude was typified by the following example:

15.2 In 1985, liquid Tritium discharges from the Hinkley A Station were increased following work to clean the coolant circuit. The 1985 discharge was 23 TBq, compared to previous years when the annual liquid discharge of Tritium from this station was less than 1 TBq per year. (Ref 27)

15.3 Despite the observed 23 fold increase in tritium discharges in 1985, the regulatory authority stated that: “the increased discharges were of negligible radiological significance” (Ref 28)

15.4 However by 1999 this approach appears to have been under review, when a more precautionary position began to appear when reference was made to the “relatively high levels of organically bound tritium (OBT) in local fish and shellfish” from the Cardiff area of the Bristol Channel/Severn Estuary (max of 33,000 Bq/Kg in cod and 26,000Bq/Kg in mussel). (Ref 29)

15.5 It was also reported that additional sampling of tide washed pasture and wildfowl (Curlew, Pintail, Shelduck and “duck”) that feed in the Bristol Channel/Severn Estuary intertidal zone had found elevated levels of tritium in most samples with:

(a)lowest wildfowl concentrations at 2,400 Bq/Kg;

(b)“the highest values found were in Shelduck at about 61,000Bq/Kg total tritium”;

(c)grass concentrations ranging from less than 3 Bq/kg to 2,000Bq/Kg; and

(d)intertidal sediment concentrations ranging from 18Bq/Kg to 2,500Bq/Kg.

While the ambient sea water concentrations of total tritium were reported to range from 9.2 Bq/Kg to 10Bq/Kg: thus representing an extremely high rate/level of biological accumulation of total tritium (assumed to be OBT + tritiated water)

15.6 In the context of these findings it was reported that research and further sampling were underway “to examine the mechanisms by which tritium becomes incorporated into biota in the marine environment” (Ref 29)

15.7 A follow on study of the behaviour of Tritium (3H) in the Severn Estuary and Bristol Channel (published in 2001) found that:

(a)Tritium concentrations in sea water from the Atlantic approaches to the Bristol Channel is estimated to be less than 0.4 Bq/Kg.

(b)Measured Tritium concentrations in sea surface water samples at the mouth of the Bristol Channel were lower than the detection level of 2 Bq/Kg.

(c)Measured Tritium concentrations in seawater inside the Bristol Channel were at their highest (between 2 and 10 Bq/Kg) on the English side of the Bristol Channel in the vicinity of the Hinkley Nuclear Power Station outfalls.

(d)Measured Tritium concentrations reached their Bristol Channel second highest concentrations (between 2 and 7Bq/Kg) in the vicinity of the Cardiff outfalls.

(e)In general, measured concentrations were at their most elevated (2 to 5Bq/Kg) in the eastern end of the sea area and at their least elevated to the west of the Hinkley discharge points. (Ref 30)

15.8 The 2001 study also reported that marine organisms incorporate Tritium, via exposure to tritiated water, very rapidly and, within a range of a few minutes to a few hours and reach concentrations close to that of the tritiated sea water in which they are immersed or from which they are acquiring their food.

15.9 These are highly significant findings in the context of the information discussed in 14:7 above. If there were to be discrete pulses or peaks (individually consisting of as much as 21% of annual discharge limit) of liquid tritium discharge, it follows that tritium concentrations in marine organisms, with their very rapid incorporation rates, will be subject to similar time related peaks of concentrations of tritium.

15.10 From the information currently available it remains unclear whether the various assumptions for delivered doses of tritium have been based on steady state delivery of liquid tritium discharges to the Hinkley marine environment or whether they are based on the peaks and troughs of tritium discharges implied by NNB Genco’s statements.

15.11 The 2001 study also found that:

(a)tritium becomes incorporated into the organic matter of cells and becomes Organically Bound Tritium (OBT), but at a slower rate than above and typically reaches a concentration of about half that of the ambient tritiated seawater;

(b)Organisms which consume tritiated food accumulate OBT at a faster rate than those exposed only to tritiated water and may reach higher concentrations by bio-accumulation;

(c)environmental monitoring through out UK waters demonstrates that concentrations of 3H in seafood in the Bristol Channel/Severn Estuary sea area are significantly greater than in other UK marine areas;

(d)there was an observed disparity in the rate and degree of Tritium bioaccumulation between sediment, seaweed, benthic (seabed) organisms and fish; however this was provisionally attributed to different processes of Tritium uptake by different species; and

(e)that bioaccumulation of tritium by benthic organisms and demersal fish occurs primarily via transfer up through a web of sediment dwelling microbes and meiofauna, which had been feeding on organic bound tritium. In this context it was observed that herbivorous species and pelagic fish had lower concentrations of tritium than carnivores and demersal (dwelling near the sea bed) fish. (Ref 30)

16. More Recent Research on the Fate and Behaviour of Tritium Diischarged to Sea

16.1 A more recent study (published in 2009) has built upon the emerging understanding of the behaviour and fate of tritium in the marine environment illustrated above and reports that:

(a)tritium’s reactivity with organic materials and solids in the marine environment had previously been “assumed to be limited”; and that

(b)previously, the accumulation of tritium in organic rich sediment and the food chain of the Severn Estuary “including concentration factors in excess of 100,000 for demersal fish and shellfish, were ascribed to the existence of organically bound tritium (OBT) in local nuclear waste in the form of specific bio-chemicals, including carbohydrates, vitamins and amino-acids”.

16.2 However, the 2009 research demonstrated that, contrary to this assumption, the research “found that its distribution appears to be influenced by its affinity for organic matter” and that “Significantly, a measurable fraction of sorbed tritium associates with proteinaceous material that is potentially available to sediment-feeding organisms.”

16.3 It was also noted that the discharge of tritiated water from a nuclear establishment on the Tamar estuary resulted in the immediate dilution to activities of less than 10 Bq per Kg in ambient water, “whereas corresponding activities of about 300Bq/Kg (dry weight) in sediment” where observed.

16.4 In the context of the above effect (which has been noted in this and other, estuarine waters) it was reported that the research absorption and adsorption (sorption) experiments had demonstrated that “sediment organic matter is critical to the removal of tritium from the aqueous phase” and that the effect “was greater in seawater than in river water”

16.5 The 2009 study noted that “the most remarkable aspect of our investigation is the extent of associated tritium, with both dissolved HOM (hydrophobic organic matter) and fine estuarine particles”.

16.6 “Experimental results, suggest that the presence and nature of organic matter is critical to the fate of tritium in the aquatic environment, and that there is also potential for its interaction with and uptake by inorganic phases. Association of tritium with sediment organic matter was corroborated in our studies by its near complete (greater than 95%) digestion in untreated estuarine particles”

16.7 Noting that “these characteristics have not been reported previously”, the 2009 study concluded that:

“Clearly the view that tritium occurs exclusively as tritiated water and therefore dissolves to infinity should be considered cautiously. Further research into the concept and nature of tritium partitioning in natural waters is required, and the adoption of unit value (or sub-unit value) distribution coefficients and concentration factors that are currently recommended by the IAEA, but not supported by clearly defined measurements, may require reconsideration.”

(Ref 31)

N.B. It is relevant to note that, as late as this 2009 study, academics were still commenting on the fact that there was a perception that radioactive wastes discharged to sea would dissolve “to infinity”.

17. Summary conclusions on Tritium:

17.1 Aqueous tritium discharged to sea rapidly mixes with surface water and behaves like any other water. Thus there are good technical grounds for assuming that it will transfer easily from the sea to the land in marine sea sprays and aerosol droplets.

A search of “Science Direct” has been unable to find any publications/references for the subject “Tritium in sea spray and marine aerosols”, this Submission therefore concludes that there is little, or no, published research on this subject.

17.2 NNB Genco states that there are no available techniques to remove tritium from reactor coolant and thus, to avoid the build up of tritium in the coolant, a portion of the coolant must be discharged to sea and replaced. (ie reactors cannot be safely operated without the discharge of tritium)

NNB Genco say that discharge strategies are normally decided by the site operator and that they will identify the preferred management strategy regime before the start of operational management of the plant.

17.3 The chosen management strategy for proposed new liquid tritium discharges at Hinkley appears likely to be based on that employed at EDF reactors in France, where discharges are pulsed rather than continuous. NNB Genco statements imply that this may be the chosen strategy at Hinkley.

17.4 If such a strategy is employed at Hinkley this could lead to as much as 21% of annual discharge being discharged in 1 month, leading to major peaks and troughs of discharge across a 12 month period. It follows that tritium concentrations in marine organisms, with their very rapid tritium incorporation rates, will be subject to similar time related peaks of concentrations of tritium.

17.5 From the information currently available it remains unclear whether the various assumptions for delivered doses of tritium (via seafoods) have been based on steady state delivery of liquid tritium discharges to the Hinkley marine environment or whether they are based on the peaks and troughs of tritium discharges implied by NNB Genco’s statements.

17.6 The previous hypothesis was that tritium would disperse and dilute to infinity after discharge into the Bristol Channel marine environment and hence that tritium discharges were of negligible significance.

NB This hypothesis is a re-iteration of the original hypothesis for the behaviour and fate of all radioactive wastes discharged to sea.

17.7 However, the evolving (post 2000) empirical research now demonstrates that, contrary to the previous view:

(a)tritium does not disperse and dilute to infinity;

(b)tritium rapidly bonds with suspended organic/sedimentary particles in the receiving waters;

(c)tritium concentrations in fine sediment deposits are significantly elevated over those found in ambient seawater;

(d)tritium bio-availability is much greater than expected; and

(e)uptake through organic/sedimentary particles to marine and estuarine food webs is demonstrated to be much higher than was expected, (tritium concentration factors in demersal fish and shellfish of up to 100,000).

17.8 As a result of these and other findings independent researchers have stated that:

(a)existing IAEA recommendations are not supported by clearly defined measurements;

(b)the adoption of unit value (or sub-unit value) distribution coefficients and concentration factors currently recommended by the IAEA may require reconsideration; and

(c)further research is required.

17.9 It is highly relevant to note that the actual annual discharges, and annual limits for discharges, of Tritium from the Bristol Channel nuclear power stations, had been markedly reduced, over the decade prior to nuclear new build applications, in response to the evolution of the understanding of tritium.

Thus, in 1999, the combined Hinkley A and B station Tritium actual discharge was 355.8TBq (RIFE 5).

But by 2009 the combined Hinkley Point A&B station Tritium discharge was reduced to 105.232TBq (RIFE 15)

17.10 However the Regulating Agency has now concurred with the demand for a reversal of that recent policy and thus

(a)If the proposed new Hinkley and Oldbury reactors come on line, tritium discharge limits (for combined existing and new Bristol Channel NPSs) will rise by 50% from 653 TBq to 983 Tbq per annum and

(b)If the proposed new Hinkley and Oldbury reactors come on line the actual annual discharge of tritium (for combined existing and new Bristol Channel NPSs) will rise from 105.4 TBq to 314.6 TBq per annum (3 fold rise)

17.11 A Subchapter of NNB Genco’s Radioactive Substances Regulation Submission Hinkley Point C: Chapter 12.2 says that

(a)Initial Radiological Assessments (IRA) provided by the Environment Agency have been used to determine environmental concentrations and doses to the public.

(b)the general methods used in IRA are described in the EC Guidance Document Radiation Protection 72 published in 1995. (Ref 32)

(c)In 1998, UK Agencies (NRPB, E.A etc) initiated use of the modelling system PC CREAM 98 as a tool for carrying out radiobiological impact assessments according to the methodology detailed in “Radiation Protection 72” and this is referenced as the modelling system for the hypothetical calculation of environmental concentrations and doses to the public arising from the proposed Hinkley C liquid discharges. (Ref 33)

17.12 To date it remains unclear whether the calculations/modelling of the behaviour and fate of tritium in the Bristol Channel environment and subsequent doses of tritium of tritium to Bristol Channel populations are based on:

(a)the use of models, methodologies and empirical data based on the most recent (2009) reported field and laboratory research and defined measurements;

(b)the use of models, methodologies based on the pre 2000 false hypotheses;

(c)the use of models, methodologies and hypothetical data “not supported by clearly defined measurements”; and

(d)the recommendation that further research is required.

17.13 N.B. To date, the available empirical monitoring/sampling data (as presented in RIFE reports) on the concentrations of Tritium in seawater, sediments and biota appears to be restricted to relatively small areas adjacent to points of discharge.

Thus there remain huge data gaps concerning the mid and far field behaviour and fate of tritium in marine environments.

18. Flawed Modelling

18.1 It is a well understood principle that the accuracy and reliability of hypotheses and hypothetical models is strictly dependant upon both the amount and the accuracy of input data.

18.2 Earlier sections of this Submission have drawn attention to the following issues.

(a)the demonstrable weaknesses in the original hypothesis about the behaviour and fate of radioactive wastes discharged to sea (sections 1 to 4);

(b)the failure/inability of monitoring programmes (based on the failed hypothesis) to generate appropriate accurate data on the behaviour and fate of radioactive wastes discharged to sea. (sections 5 to 8); and

(c)the absence of data (data gaps), and/or issues not taken account of during GDA and other assessments of the marine implications of proposed sea discharges from proposed NPS. (sections 9 to 17)

18.3 In the context of these flaws, failures and omissions this Submission concludes that any hypothetical modelling programmes which repeat and encapsulate those flaws, failure and omissions must be of questionable value and can not represent an appropriate degree of scientific rigour.

18.4 The NNB Genco Submission for the Hinkley C proposed discharges (NNB-OSL-REP-000147 Sub Chapter 12:2) explains that the general methodology used to calculate environmental concentrations of radioactivity and the doses derived from those concentrations is described in the EC guidance document Radiation Protection: 72 RP72.

It is explained that RP72 describes what is defined as a “comprehensive model” called the Consequences of Releases to the Environment Assessment Methodology otherwise know as CREAM. This model was developed as a tool for carrying out radiological impact assessments.

18.5 This Submission draws attention to the fact that RP 72 was first published in 1995 and that the edition of the CREAM model, used by the Environment Agency and the HPA’s Radiation Protection Division and referenced by NNB Genco for use during the assessments of outcomes for the proposed Hinkley C UK EPR station liquid discharges, is PC CREAM 98

18.6 However, the website address:

www.hpa-radiationservices.org.uk/pccream/featureoverview

Introduces PC-CREAM 08 which is stated to be “a significant improvement to the PC-CREAM 98 version of the software because it takes into account feedback from users and recent model developments”.

NNB-OSL-REP-000147 (page 8: sub chapter 12.2) specifically states “The PC CREAM 08 model was not available when the assessment process was undertaken”.

Furthermore the HPA’s Radiation Protection division is on record as stating that, as of February 28^th 2010 it will no longer be committed to providing support for PC CREAM 98.

18.7 This Report therefore concludes that, in the context of the evidence above, it is evident that the PC CREAM 98 modelling software should be considered redundant This Report also concludes that since the assessment process was evidently undertaken some time ago it may therefore not be fully informed about the latest consensually agreed advances in radiological science regarding a range of issues discussed by this Submission (Tritium for instance).

18.8 NNB-OSL-REP-000147 (page 8: sub chapter 12.2: fifth paragraph) states “All discharges are assumed to be continuous, uniform, routine releases”. This, as is explained above, applies to the modelling conducted under PC CREAM 98.

However, as shown in earlier sections of this Report, discharges of some nuclides from the proposed Hinkley C rectors are expected to be pulsed or intermittent and thus the work carried out under PC CREAM 98 will not be relevant to any such pulsed or intermittent discharges.

18.9 The Environment Agency’s GDA Assessment report UK EPR-05 (page 25: para 119) states that

“For GDA, EDF and AREVA selected Irish Sea/Cumbrian Waters for predicting dispersion of liquid radioactive discharges using the model PC CREAM. They said this would give pessimistic results for the dose impact calculations”. The Environment Agency GDA Report does not question the assumption.

18.10 This Submission draws attention to the fact that neither NNB Genco, EDF/AREVA, nor the Environment Agency have offered any review, discussion or examination of the statement.

This Submission has already introduced evidence to demonstrate that there are major differences between Irish Sea and Bristol Channel fine particle sediment loadings of the water column (with Bristol Channel fine sediment loadings vastly exceeding those reported for the Irish Sea and Bristol Channel fine sediments reported as being more likely to be organic in origin)

N.B. mechanisms of re-concentration of radionuclides (alpha/actinides) by adsorbtion to fine sediment particles and attachment of some radionuclides (eg tritium) to organic particles are shown (see earlier sections) to be a major factor in the behaviour and fate of sea discharged radioactive wastes.

18.11 In the context of the above, this Submission thus concludes that there is no scientific evidence to support the assumption that the choice of Irish Sea/Cumbrian Waters is appropriate to assessments for the Bristol Channel or for claims that model outcomes will be pessimistic; in fact the available evidence tends to suggest that they may well be optimistic.

This Submission thus concludes that the use of Irish Sea data in a Bristol Channel context lacks both evidential justification and scientific rigour on the part of both NPS developers and the Regulating bodies.

18.12 This Submission draws attention to the fact that the DORIS marine dispersion component of the CREAM model has been revised since the 2003 publication of the EC MARINA ll study into the behaviour of radioactivity in the marine environment, and thus assumes that these revisions are not encapsulated in PC CREAM 98.

18.13 This Submission also notes that a research study with the working title “Identifying Key Parameters which Control Coastal Dispersion Modelling” has been under way for some time, was originally supposed to be published in 2010 but had not yet been published.

Although this study has been variously attributed to the Environment Agency, the HPA and the National Dose Assessment Working group and is referenced as ongoing in several websites, inquiries to each body, while confirming that such a research project is underway, have been unable to clarify either the authors, the proposed date of completion of the study or a confirmed future date of publication.

18.14 This Submission therefore concludes that the outcomes of what must be highly important research input to the modelling processes and software discussed above are still not available and thus that the modelling processes and software in question are therefore not informed by the latest subject specific research.

18.15 This Submission re-iterates the fact that, in order to generate the most reliable and accurate hypothetical models of the behaviour and fate of radioactive wastes discharged to sea, models of potential pathways of dose delivery to the public and models of potential actual doses received by the public, it is imperative to input the most recently identified, accurate, reliable and up-to-date data and understanding of all relevant parameters.

18.16 This Submission draws attention to the fact that, in the context of the issues set out in preceding paragraphs of this section, the various modelling programmes concerning the environmental behaviour and fate of marine discharges radioactive wastes, pathways of exposure and the subsequent doses of radioactivity to the public are not informed by the most recently identified, accurate, reliable and up-to-date data and understanding of all relevant parameters.

18.17 This Submission draws attention to the fact that although hypothetical models are generally calibrated against observed data, in this case much of the existing observed data is deeply flawed because it is based on the catalogue of errors set out in preceding sections of this Submission and summarised in 18:2 above.

18.18 This Submission therefore concludes that the entire suite of hypothetical models upon which the proposed “safety” of the proposals to discharge radioactive wastes to sea are based are significantly flawed for the reasons set out above and that their use by NPS developers and the Regulating agencies has little or no evidential justification and has demonstrated a lack of scientific rigour.

19. Potential Marine Environments Outcomes of Fukushima Type LOCA/Emergency Coolant Water Use at New Build NPS.

19.1 In the aftermath of the Fukushima incident the UK and Northern Ireland Nuclear Free Local Authorities submitted a large body of evidence to the Weightman Inquiry into the lessons to be learned from that incident.

19.2 One of the issues covered by the NFLA’s submission to Weightman was that of the major radioactive pollution of the adjacent marine environment as a result of

(a)the initial series of Loss of Coolant water Accidents (LOCA) at the plant;

(b)followed by the use of enormous volumes of Emergency Cooling Water (ECW) in order to prevent reactor and cooling pond meltdowns;

(c)the lack of systems for the management, control, capture and storage of the huge volumes of radioactive liquid which arose; and

(d)leading to the runoff (to adjacent watercourses, the sea and adjacent land surfaces) of the contaminated liquids.

19.3 This Submission draws attention to the fact that the occurrence of LOCA events are not restricted to the 2011 Fukushima incident where multiple Reactors and Spent Fuel Cooling Ponds (SFCP) suffered catastrophic loss of their coolant.

Other examples of LOCAs are the Windscale fire of 1957, the Mayak Reprocessor SFCP (USSR) 1957, the Lucens reactor (Switzerland) 1969, Three Mile Island (USA) 1979 and Chernobyl (USSR) 1986.

A majority response to such events (in order to avoid a melt down and subsequent major release of radioactivity to the atmosphere) is to use ECW as a preventative measure and to keep on applying ECW until the situation is fully under control.

19.4 Despite the past history of LOCA occurrence and the consensual conclusion that they are caused by human fallibility (designer or operator error) in the face of unforeseen events, neither the Proposals submitted by the developers of proposed new NPS nor Regulating Agency’s GDA Aqueous Radioactive Assessment Reports have bothered to address Loss of Coolant Accidents (LOCA) in the context of the behaviour, fate and management of primary and secondary cooling waters in the event of a LOCA event.

Additionally, neither have addressed the response necessary for the management of potentially massive Emergency Cooling Water (ECW) arisings, and neither have carried out an analysis of the potential damage impact to site infrastructure, storage tanks or drainage systems due to unforeseen circumstances responsible for LOCA events.

19.5 The GDA Aqueous Radioactive Assessment Reports also fail to address the issues surrounding the necessity for the provision of capture/retention/treatment capacity for hundreds of thousands of cubic metres of ECW generated over prolonged time scales.

19.6 It is evident that the information given in the GDA’s Aqueous Radioactive Assessment Reports is relevant to only “normal operations” and contains no discussion of specific issues arising in the event of reactor or cooling pond LOCA events requiring the use of Fukushima type volumes of Emergency Cooling Water (or severe flooding of sites as a result of such phenomena as tidal bore, storm surge, tsunami, excessive rainfall).

19.7 The following extracts from the GDA for the proposed Hinkley C UK EPR are relevant:

“We have not considered at GDA other site liquid discharges such as surface water. The design of such systems will be site specific and there should be no contamination in normal operation. We will review site drainage at site specific permitting and, as a minimum, require accessible sampling points at final discharge locations for confirmation spot sampling.”

(Ref 39)

19.8 Annex 1 (Fig 1) of Ref 39: shows collection and management of three liquid effluent streams:

(a)Primary Liquid Effluent.

(b)Spent Liquid Effluent.

(c)Drainage Water from Turbine Hall.

19.9 In their GDA for the Oldbury type AP 1000 reactor, the EA list five sources of aqueous radioactive waste (Paras 35–46)

(a)Reactor Coolant System Effluents.

(b)Building floor drains and sumps.

(c)Detergent wastes (sinks, showers etc).

(d)Aqueous chemical wastes (laboratory and other small volume sources).

(e)Steam Generator blowdown wastes.

(Ref 40)

19.10 And at Page 15: Para 49 of Ref 40 EA says “We consider that all sources of aqueous radioactive waste have been identified”.

And at Para 57 (page 16) EA say “AP1000 has five types of tanks for collecting aqueous radioactive waste”:

(a)	Reactor Coolant drain tank	volume= 3.4 cubic metres
(b)	Effluent Hold up tanks	volume= 2 x 106 cubic metres
(c)	Waste hold up tanks	volume= 2 x 57 cubic metres
(d)	Chemical waste tank	volume= 34 cubic metres
(e)	Monitor tanks (42 days storage)	volume=6 x 57 cubic metre
TOTAL VOLUME		=705’4 cubic metres

19.11 It is evident that the information given in the GDA’s Aqueous Radioactive Assessment Reports is relevant to only “normal operations”.

Thus the GDA Aqueous Radioactive Assessment Reports fail to address LOCA response and the potential for massive Emergency Cooling Water (ECW) arisings, and do not conduct an analysis of the potential damage to site infrastructure, storage tanks or drainage systems due to unforeseen circumstances.

19.12 The GDA Aqueous Radioactive Assessment Reports fail to address the issues surrounding the necessity for the provision of capture/retention/treatment capacity for hundreds of thousands of cubic metres of ECW generated through the post LOCA period and, in the case of the Fukushima site, still underway over a year after the initial event.

(See Annex 1 for a detailed breakdown of the Fukushima post tsunami events and issues relating to production and management of post event highly radioactive waters)

Similarly the various submissions by the developers of both UK EPR and Westinghouse/Toshiba AP1000 also fail to consider the control and management of any ECW arisings in the event of a LOCA response

19.13 The Nuclear Free Local Authorities (NFLA) have already submitted information to the ONR Weightman Inquiry on these issues and made the following recommendations:

(a)Site drainage (with specific relevance to emergency situations including LOCA response and inundation) should be made a GDA and major planning issue and NOT be determined by site operators, on a site specific basis.

(b)The GDA should review reactor basement design and construction in order to confirm that, if they are to be used for collection and storage of spilled reactor and/or cooling pond coolant and ECW, they will prevent leaching, facilitate the monitoring of the Highly Radioactive Water (HRW) and escaped coolant and be provided with appropriate equipment such as pumps, gauges etc.

(c)HRW capture/retention, storage and treatment capacity should be made a GDA issue and NOT be determined on a reactor specific or site specific basis. It should be thoroughly reviewed for all proposed Nuclear New Build (and also existing sites) in the context of both:

1.the Fukushima event; and

2.the potential LOCA events and the potential for tsunami/flood events.

(d)The storage capacity for highly concentrated wastes generated by the filtration treatment of HRW should be reviewed by the GDA with a view to ensuring that, in the event of the need to filter treat high volumes of escaped coolant and contaminated ECW, there is sufficient storage capacity for the ensuing highly concentrated radioactive waste

19.14 This Submission draws attention to the fact that prior to the (listed above) LOCA events, the occurrence of LOCA was generally reported and assumed to be unthinkable and therefore programmes for the management and control of lost primary and secondary coolants and subsequent emergency cooling waters were not put in place

In a similar vein, as can be seen from the paucity/lack of available relevant and appropriate data about the marine/aquatic impacts of the Fukushima events, no provision was made for pre-planned programmes of emergency environmental monitoring.

19.15 This Submission concludes that a similar industry and regulator mind set is now in place with regard to the current proposed UKEPR and AP1000 PWRs but warns that there is no evidence to justify such an assumption,

This Submission further concludes that, on the contrary, the available evidence from the previous events demonstrates the very real need for the precautionary installation of

(a)appropriate site infrastructure;

(b)strategies and procedures for the containment and management of lost coolants and emergency cooling waters; and

(c)pre-planned programmes for emergency monitoring of all aspects of aquatic and marine environments.

References

1. “Disposal of Radioactive Wastes: a review of IAEA efforts to assure safety”. IAEA Bulletin Vol 03: Issue 3. 1961. (page 3).

2. Statement by John Dunster (UKAEA) to the United Nations Conference “Peaceful Uses of the Atom” 1958

3. Cooperative Research Report 155, ICES, Copenhagen, 1989: International Council for the Exploration of the Seas

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39. Environment Agency. GDA ASSESSMENT Report UK EPR-05. Assessment Report: Aqueous Radioactive Waste Disposal and Limits. Page 25: para 118.

40. Environment Agency. GDA ASSESSMENT Report AP1000 Assessment report: Aqueous Radioactive Waste Disposal and Limits.

Annex 1

RECOMMENDATIONS ARISING FROM LESSONS LEARNED FROM THE FUKUSHIMA DAIICHI EVENT

A Report to the Nuclear Free Local Authorities for submission to the Weightman Inquiry

September 2011

Tim Deere-Jones: Marine Radioactivity Consultant: August 2011.

Introduction

The foci of this submission are

1. The events preceding and giving rise to the discharge of LOCA derived radioactive material to the marine environment adjacent to the outfalls of the Fukushima

2. Attempts to control and manage both the coolant water which escaped from reactors and spend fuel cooling ponds (Scups) and the emergency cooling water (ECW) used to respond to the loss of that coolant

3. Attempts to identify and quantify the radioactivity discharged to the environment (in liquid/aqueous form) during the event

4. Attempts to monitor the marine environmental impacts of the radioactivity discharged during the events.

I have placed the Recommendations first.

A brief review of the chronological and factual aspects of the Fukushima Daiichi follows the Recommendations.

That brief review tries to

(a)clarify a mass of poorly reported and often contradictory facts;

(b)to develop a time line of events as they relate to discharges to sea; and

(c)to identify weaknesses/failures in procedures, management and response to the event.

Recommendations in Light of FUKUSHIMA Experience:

1.1 Despite assessments of the full range of potential threats the Fukushima event was not foreseen and safety measures designed and built in to the plant during it’s initial construction and during subsequent years were not adequate to the task of preventing the event.

1.2 Thus the event demonstrates that no matter how much statistical analysis is applied to such issues in order to attempt to forecast potential threats, human fallibility will never be able to guarantee identification of all possibilities.

The only guarantee is that totally unexpected events will occur. This is the most important lesson to be learned from the Fukushima event.

Site Drainage Infrastructure and Management

2. Responding to initial loss of coolants

2.1 The Fukushima accident demonstrated that in the event of catastrophic LOCAs at either Reactor units and/or Scups (Spent Fuel Cooling Ponds), large volumes (up to the total volume contained within the units) of highly radioactive Primary and Secondary coolant can be lost from both Reactors and pond containment systems as a result of single (earthquake) and multiple events (earthquake+ tsunami), and presumably any other similar magnitude “shock” or “flood” incidents, causing disabling damage and loss of function to infrastructure and operating systems.

2.2 Having escaped from the engineered containment systems, liquid (as opposed to vaporised) coolant was then able to enter non “contained” areas of the site.

2.3 The available evidence indicates that this coolant initially entered and was retained in various “basement” and “trench” sections adjacent too and/or beneath the Reactors and turbine halls. No evidence has been offered to demonstrate that such basement areas were specifically designed and engineered to be “fit” for this purpose. The available evidence suggests that this then gave rise to uncontrolled losses of such liquid, from “trenches” and into the marine environment.

3. Recommendations for management of initial coolant losses

3.1 In the event of a Reactor or SFCP LOCA it is evidently necessary to have in place a system of Emergency Catchments/Containment systems to prevent the total escape, and loss of control, of leaking Primary and Secondary coolant.

3.2 Thus each unit or facility (Reactor, SFCP, high level liquid waste storage) should be equipped with sufficient emergency catchments space to capture and hold the entirety of coolant from the relevant source.

3.3 This emergency catchments should be sited as low as possible in order to collect escaping coolant on a gravity flow basis (with engineered flow assisting channels) and thus maximise the amount of escaping coolant which can be collected in the event of site-wide mechanical and electrical failures.

3.4 Such emergency catchments should be sealed from “outside” non-LOCA parameter sources such as heavy rainfall, flood or tsunami.

Such emergency catchment should be engineered to the highest standards of accident survivability.

3.5 Such emergency catchment should be equipped with it’s own integral pumping system to facilitate removal of this material to safe long term storage. Additionally it should be provided with the facility to easily and simply attach “emergency” pumping equipment if so required

3.6 Such emergency catchment should be equipped with it’s own integral radiation level readers and also with sampling equipment enabling thorough radiological analysis of the contents of the emergency containment to be carried out. Additionally it should be provided with the facility to easily and simply attach “emergency” sampling equipment if so required.

4. Responding to outcomes of Emergency Cooling Water Use

4.1 The Fukushima event has demonstrated that, in the event of catastrophic LOCAs at Reactor and SFCP units, a primary and very long term response is the application of high volumes of Emergency Cooling Water (ECW).

4.2 It is evident that the scale of use of ECW gave rise to an additional series of problems surrounding the management and control of ECW

4.3 The available evidence suggests that, having been passed through/over fully or partially melted fuels in Reactor cores and SFCPs, the ECW initially entered the various “basement” and “trench” sections beneath the Reactors and turbine halls where it must be assumed to have mixed with the initial lost coolant.

4.4 There is a wide discrepancy between the combined volume of liquid radioactivity reported to have escaped from “trenches” and that deliberately discharged from pre-event liquid waste tanks in order to store more highly active liquid wastes generated by coolant loss and ECW use, when compared to the total volumes of ECW used as discussed in the main body of this submission.

4.5 Continuous application of ECW plainly led to the eventual spread of liquid radioactivity into other sectors of the site and hence into the marine environment.

5. Recommendations re control and management of ECW

5.1 In the event of a catastrophic LOCA requiring the application of massive volumes of ECW, measures are required to prevent the ECW from reaching the marine environment.

5.2 Where ECW is being applied to ruptured/breached reactors and SFCPs, the Emergency Secondary Catchment systems proposed above might be used if they were of sufficient volume to hold that coolant lost during the initial LOCA + the additional ECW.

5.3 However, in the case of an incident such as the Fukushima event, it is evident that the huge volume of ECW (reportedly 1,000’s of tonnes) would likely quickly overwhelm any basic LOCA emergency catchment systems unless they were specifically engineered to hold such high volumes.

5.4 Controlling flow and end fate of ECW poses additional problems in the context of the “exterior use” of ECW which was applied to reactor roofs (and possibly SFCPs) by helicopter drop, riot control water cannon and fie trucks in scenarios which might exclude the collection of excess ECW etc in the proposed emergency catchment systems while generating free flowing (uncontrolled) run off of ECW.

5.5 Such difficulties could be circumvented if the initial site design and build process were to ensure that all areas in the vicinity of potential sources of radioactive material (including potential internal and external applications of ECW) were to be fully bunded and provided with gravity driven run off/drainage control systems including extensive and very high volume holding tanks such that NO site liquid run offs would be uncontrolled (ie ALL surface liquids generated within the site: including LOCAs, ECW, all rainfall and any other spills, would be controlled).

5.6 In order to combat a scenario like the Fukushima event such holding tanks would have to be numerous and large with the capacity to hold many 1,000s of tonnes of radioactive liquid.

5.7 Such high volume holding tanks should be engineered to withstand as best as possible, all flood and shock events, provided with inbuilt pumping systems enabling the transfer of liquids from one to the other and provided with the facility to easily and simply attach “emergency” pumping equipment if so required

5.8 In addition to providing management options for the control of ECW etc, the use of such tanks would have the additional benefit of catching and containing long term (late discovered) leaks of radioactive liquids via site drains, such as has been recorded at UK reactors under normal operational conditions.

(see Appendix 1: “Incomplete discharge Data”: para 4)

5.9 All such high volume tanks should be fitted with their own integral radiation level readers and also with sampling equipment enabling thorough radiological analysis of the contents of the tanks to be carried out. Additionally they should be provided with the facility to easily and simply attach “emergency” sampling equipment if so required.

5.10 Use of such tanks to prevent direct run off of LOCA, ECW and other radioactive (or potentially radioactive) liquids in to marine and other environments would thus permit control of the initial event and an appropriate level of management of the liquid wastes thus generated (including: thorough investigation of the radioactivity content of retained liquid, controlled discharge of low level liquids, appropriate control and manipulation of liquids in the process of decaying to acceptable levels, retention and treatment of high level liquids and settlement of particulate matter)

5.11 Additional issues thrown up by the Fukushima event include that of the application of sea water as ECW with subsequent damage and the reduction of efficiency of reactor and SFCP pipe work due to salt clogging of pipe work etc, which led to a reduced flow of water through Reactor and SFCP systems. Such impacts can be avoided by the use of freshwater instead of salt water.

5.12 The reporting of the Fukushima event makes it plain that freshwater sources were depleted very soon after the event began. Plainly, any future reactor site design must include provision for unbroken supplies of freshwater, best achieved by having both on site and regional reservoirs of freshwater dedicated to the task of coolant replenishment.

5.13 Ready access to regional supplies is necessary in order to avoid the total loss of supply in the event that on site supplies are overwhelmed.

Replacement emergency delivery systems (pumps and pipe work) must be installed or immediately available in order to avoid the catalogue of delays and interruptions to supplies reported during the Fukushima event.

6. Post event monitoring of marine environments

6.1 The purpose of post event radiological monitoring and analysis of the environment is to assess the public health impact and the behaviour and possible fate of all of the radioactivity discharged during the event

6.2 Post Fukushima type event scenarios require the rapid deployment of thorough and coherent monitoring and analytical programmes designed to investigate the concentrations and behaviour and fate of the full inventory of radioactive materials likely to have been discharged during the event.

6.3 The post Fukushima event monitoring and analysis of the marine environment was characterised by late inception, restricted frequency and limited investigation of limited parameters. It appears to be representative of a rushed, panicky and incoherent response to unforeseen circumstances.

6.4 The Fukushima monitoring/analytical programmes have failed to ct to comprehensively (or even adequately) investigate the full inventory of potential radioactive pollutants in that they have focussed almost exclusively on Iodine and Caesium isotopes, while ignoring many others especially the alpha emitting actinides known to be present in BWR reactor cores and SFCP (several isotopes of Plutonium, uranium, curium, americium).

7. Recommendations for post event marine monitoring programmes

7.1 Any future monitoring and analysis, following a Fukushima type event must fully take into account the full inventory of radioactivity available for release given the nature of the accident and the actions taken.

7.2 At Fukushima the monitoring authorities chose to focus on those isotopes (iodine and Caesium) which are highly soluble in water, while at the same time ignoring those which are insoluble and prefer to attach by Adsorbtion to sedimentary particles suspended in the water column.

7.3 They also failed to investigate the presence, concentration and radiological significance of “hot” particles of reactor fuel, used fuel from cooling ponds and/or pieces of reactor of cooling pond structure released into coolant and ECW flows as a result of explosion, meltdown, containment breach, washout of coolant and through flow of ECW.

7.4 In order to adequately fulfil the purpose of future post (reactor and Cooling Pond) LOCA marine monitoring and analytical programmes those operators and agencies responsible for drawing up such programmes should prepare A CLEAR AND DETAILED POST EVENT MONITORING AND ANALYTICAL PROGRAMME, subject to wide scrutiny and peer review and available for immediate deployment in the event of such an event

7.5 Such a programme should take account of the following parameters

(a)the full inventory of radioactive materials contained within both Reactor cores and spent fuel ponds;

(b)any monitoring and analytical work should include coverage of both beta emitters and alpha emitters, activation products and fission products; and

(c)accident derived “hot” particles (pieces of fuel from reactors and/or cooling ponds subject to explosion or meltdown, materials likely to have escaped from reactors of SFCP as a result of coolant escape and the use of ECW).

7.6 Such a programme should take account of the known environmental behaviour of both highly soluble radioactive materials and non-soluble radioactive materials with regard to both their immediate behaviour and long term behaviour and fates.

Such a programme should investigate the behaviour of radioactivity by filtering seawater samples and identifying the concentrations of the inventory radioactivity found in filtered seawater and that found in any sedimentary particles previously suspended in the seawater.

7.7 Such a programme should identify near, mid and far field end fate deposition environments (seabed and inter tidal fine sediment deposits) where very long lived, non-soluble isotopes of Plutonium, Americium, Uranium and Curium might be expected to deposit out and re-concentrate relative to ambient water column concentrations.

7.8 Such a programme should have regard to the scientifically attested work which has demonstrated the ability of several isotopes (both highly soluble and in-soluble and in particulate form) to re-concentrate in marine micro layers, marine sea sprays and marine aerosols and hence to transfer from the sea to the land. Analytical work to assess the post event Public Health significance of these mechanisms must be undertaken, leading as they do to potential human exposure via inhalation, contact etc.

7.9 Such a programme should also have regard to the attested fact that such isotopes (including Caesiums and actinides and particulates) have been shown to transfer from the sea to the land (via sea spray, aerosols, flooding) and to contaminate terrestrial foodstuffs and thus enter terrestrial dietary chains. Analytical work to assess the Public Health significance of these mechanisms must be undertaken in the context of potential exposure of humans via pathways of ingestion, inhalation and contact.

7.10 Such a programme should also have regard to the fact that radioactivity deposited in inter tidal sedimentary environments has been shown to be susceptible to re-suspension (in drying conditions) and blowing ashore adsorbed to fine sediment particles to contaminate house dust and perhaps terrestrial foodstuffs

8. Recommendations arising from EAs GDA statements that site drainage issues should be determined on a site specific basis

8.1 Site drainage (with specific relevance to emergency situations including LOCA response and inundation) should be made a GDA issue and NOT be determined on a site specific basis.

8.2 The GDA should review reactor basement design and construction in order to confirm that, if they are to be used for collection and storage of spilled reactor and/or cooling pond coolant and ECW, they will prevent leaching, facilitate the monitoring of the HRW and escaped coolant and be provided with appropriate equipment such as pumps, gauges etc.

8.3 Highly Radioactive Water (HRW) capture/retention, storage and treatment capacity should be made a GDA issue and NOT be determined on a reactor specific or site specific basis. It should be thoroughly reviewed in the context of the Fukushima event

8.4 The storage capacity for highly concentrated wastes generated by the filtration treatment of HRW should be reviewed by the GDA with a view to ensuring that, in the event of the need to filter/treat high volumes of escaped coolant and contaminated ECW, there is sufficient storage capacity for the ensuing highly concentrated radioactive waste

Description/Chronology of events at Fukushima Daiichi

1.1 There is now a maturing and ongoing consensus among industry commentators that the Fukushima events have been characterised by

(a)low standard of accuracy and transparency of reporting;

(b)confusion of chronology;

(c)confusion of factual detail (mistakes); and

(d)inadequate number of parameters reported.

1.2 This has led to both an inadequate understanding of the event itself and an equally inadequate management of many issues, not least those leading to the ongoing mis-management of issues concerning the marine environmental impacts of post-incident remedial actions.

1.3 As of yet there is a dearth of in-depth and peer reviewed analyses of the factual and chronological evolution of events. Additionally of course, it is undoubtedly the fact that events continue to unfold as the Inquiry hears evidence thus many of the outcomes of the Fukushima event are still unknown.

1.4 Evidently it is premature to conduct any reviews of the implications of the event (in respect of the UK’s ongoing nuclear power developments) until such time as the Fukushima events and their aftermath are universally agreed to have concluded and a wide ranging, peer reviewed analysis of what actually happened at Fukushima, and it’s full range of environmental, public health and economic impacts had been conducted and made public.

1.5 Thus, in the current context, the UK Government has acted precipitously in setting up the Inquiry and insisting on a limited time scale for conclusion and presentation of recommendations in the absence of a factually and chronologically complete, wide ranging and peer reviewed analysis of all of the available facts.

1.6 Consequently this submission relies upon the relatively “immediate” responses of various experts and commentators, which have been reported as events continue to unfold.

The following paragraphs are based on information provided by TEPCO and Japanese Government Press Releases, and a very well referenced summary of the event provided by WIKIPEDIA.

2. Loss of Reactor 1 coolant water

For brevity’s sake this submission will focus on events surrounding the 3 partial meltdown incidents at Fukushima Reactors 1, 2 and 3 all of which have required remedial injection of high volumes of emergency cooling water (ECW) supplies due to leaks following breach of containment

2.1 Reactor 1: chronology of emergency coolant water injection

(a)Within 16 hours of initial major quake: containment/cooling systems completely failed and fuel rods exposed. The reactor core had melted, fallen to bottom of pressure vessel and burned through it.

(b)12 March: (20.20 Japan Time) (JT): seawater injection to reactor core initiated using fire trucks (flow rate of 2 cubic metres per hour)

(c)23 March: Seawater injection by site feed water systems (flow rate increases to 18 cubic metres per hour)

(d)24 March: high rate of seawater injection increases pressure in reactor….steam vented and (water flow rate reduced to 11 cubic metres per hour)

(e)25 March: 1,890 cubic metres freshwater brought to site by barge and fresh water injection replaces seawater injection.

(f)12 May: TEPCO confirms that due holes in pressure vessel, coolant water continues to leak.

(g)June: Japanese Government confirms that reactor containment had been breached and that pumped cooling water continued to leak

(h)23 August^: TEPCO press release confirms that water continues to be injected at flow rate of 3.7 cubic metres per hour.

No details have been provided regarding the starting date of this reduced flow rate programme, thus militating against any calculation of the volumes of water used during this period.

2.2 I have been unable to find any comprehensive assessment of volumes of emergency cooling water use re Reactor 1. Such data appears to have not been calculated.

However the following may give some impression of the volumes of ECW used at Unit 1 (cubic metre == approx I tonne of water)

Dates	Given Flow rates	Total Volumes for period
12 to 23 March	2 cubic metres per hour	528 tonnes per 11 days
23/24 March	18 cubic metres per hour	432 tonnes per 1 day
25 March	11 cubic metres per hour	264 tonnes per 1 day
23 August report	3.7 cubic metres per hour	88.8 tonnes per day (but date of flow change not available)

2.3 Thus, after 13 days of ECW pumping (12 to 25 March) an estimated 1,224 tonnes of water had pumped into the reactor core of Unit 1 at an average rate of 81.6 tonnes per day.

2.4 During the subsequent 151 days (March 25 to Aug 23) the ECW flow rate cannot be precisely calculated due to the very poor reporting.

However, using the data presented in 2:1 (above) the range of potential values would spread from

Max Value a: 150 days at 264 + 1 day (Aug 23) at 88.8 = approx’ 39,688 tonnes

Min Value b: 151 days at 88.8 = approx’ 13,408 tonnes

2.5 Total estimated pumped ECW values for period 12 March to 23 Aug (164 days) thus range between

Value a: 39,688 tonnes +1,224 tonnes = 40,912 tonnes

(average daily rate = 250 tonnes)

Value b: 13,408tonnes +1,224 tonnes = 14,632 tonnes

(average daily rate=90 tonnes)

2:6 As of Aug 23, there has been 164 days of continuous pumping of ECW through the reactor core.

In the context of the

(a)official confirmation of meltdown beginning within five hours of the first earthquake because of cooling failure;

(b)constant application of ECW to reactor core; and

(c)confirmation of leaks in the reactor pressure vessel and containment systems.

It cannot be denied that ECW has been continuously passing over/through the reactor core (and subsequently the molten mass of fuel arising as a result of the meltdown) for 5..5 months and flushing a range of particulate and dissolved radioactive fission and activation products from the reactor core and into non-core, non pressure vessel and non-containment system environments : ie transporting those various radioactive materials from within a supposedly safe and shielded environment to the outside environment.

2.7 When reactor core cooling fails in such a scenario the zirconium alloy fuel cladding fails and fission products are released. There can be no doubt that the ECW flows will have collected a highly significant quantity of the full range of fission products and transported them in the ECW flow through the reactor core, the pressure vessel and the containment buildings to whatever their end deposition site will have been.

2.8 No comprehensive calculation, assessment or estimate of the total volume/quantity of core derived fission products entrained in the ECW through flow has yet been made public.

2.9 In the absence of any other data it may be assumed that the full range of fission products derived from uranium oxide based fuels undergoing a meltdown were available for entrainment into the ECW deployed at Unit 1.

These fission products will have included approximately 17 actinides composed of:

Several isotopes of Uranium;

Several isotopes of Plutonium;

Several isotopes of Americium; and

Several isotopes of Curium.

2.10 In addition the BWR cores will have contained isotopes of Caesium, Iodine, Tritium, and Rubidium and a cocktail of approximately 55 other radioactive isotopes (including corrosion products derived from the irradiation of reactor and pipe work structural materials as well as from the fuel and it’s cladding.)

3. Loss of Reactor 2 Cooling water

3.1 Reactor 2: chronology of emergency coolant water injection

(a)14 March : fuel rods exposed and water levels falling to minimum values.

Injection of sea water into reactor vessel initiated and reactor vessel half filled

(b)14 March : pumping stopped due to four of five pumps failed and 5^th ran out of fuel. Also gauge accidentally turned off and blocked flow of water into reactor vessel

(c)15 March: pumping resumed

(d)26 March: switch to freshwater injection

(e)28 March : Nuclear Safety Commission suspects rad’ mats leaked from reactor into water in trenches……volumes of pumped water reduced because of concern about leaks to sea

(f)15 May: TEPCO reports that Unit 2 leaking and that 1,000s of tonnes of pumped ECW had leaked

(g)23 May: TEPCO reports Reactor 2 achieved meltdown about 100 hours after initial quake

(h)August: ECW still being pumped

3.2 As of yet I have not been able to access details of the flow rates of ECW pumping flow rates. Nor have I have been unable to find any comprehensive assessment of volumes of emergency cooling water use re Reactor 2. Such data appears to have not been calculated.

However the scant available details of the progress of events at Reactor 2 imply that pumping flow rates for ECW were probably broadly similar to those at Reactor 1.

3.3 Therefore, and subject to the release of additional information, I propose that the range of Total Pumped Volume of ECW for reactor 2, be taken as similar to that of Reactor 1.

3.4 Total estimated pumped ECW values for period 14 March to 23 Aug (164 days) thus range between

value a: 39,688 tonnes +1,224 tonnes = 40,912 tonnes

(average daily rate = 250 tonnes)

value b: 13,408tonnes +1,224 tonnes = 14,632 tonnes

(average daily rate=90 tonnes)

3.5 There has now been at least 162 days of continuous pumping of ECW through the reactor 2 core.

In the context of the

(a)official confirmation of meltdown beginning due to the first earthquake because of cooling failure; and

(b)confirmation of leaks in the reactor pressure vessel and containment systems

3.6 This can only mean that water has been passing over the fuel rods and subsequently the molten mass of fuel arising as a result of the meltdown.

3.7 It cannot be denied that ECW has been continuously passing over/through the reactor core (and subsequently the molten mass of fuel arising as a result of the meltdown) for 5.5 months and flushing a range of particulate and dissolved radioactive fission and activation products from the reactor core and into non-core, non pressure vessel and non-containment system environments : ie transporting those various radioactive materials from within a supposedly safe and shielded environment to the outside environment.

3.8 When reactor core cooling fails in such a situation the zirconium alloy fuel cladding fails and fission products are released. There can be no doubt that the ECW flows will have collected a highly significant quantity of the full range of fission products and transported them in the ECW flow through the reactor core, the pressure vessel, the containment buildings to whatever their end deposition site will have been.

3.9 No comprehensive calculation, assessment or estimate of the total volume/quantity of core derived fission products entrained in the ECW through flow at Reactor 2 has yet been made public.

3.10 In the absence of any other data it may be assumed that the full inventory of fission products derived from uranium oxide based fuels undergoing a meltdown were available for entrainment into the ECW deployed at Unit 2.

These fission products will have included approximately 17 actinides composed of:

Several isotopes of Uranium;

Several isotopes of Plutonium;

Several isotopes of Americium; and

Several isotopes of Curium.

3.11 In addition the BWR cores will have contained isotopes of Caesium, Iodine, Tritium, and Rubidium and a cocktail of approximately 55 other radioactive isotopes (including corrosion products derived from the irradiation of reactor and pipe work structural materials as well as from the fuel and it’s cladding.)

4. Loss of Reactor 3 cooling water

4.1 TEPCO have announced that meltdown in this reactor occurred approx’ 60 hours after the initial quake.

In September 2010 TEPCO had announced the restart of Reactor 3 using Pu MOX fuel and Uranium Dioxide.

(a)13 March: seawater injection of Reactor core commenced using fire truck pumps

(b)14 March: pumping stopped due to consumption of water in “reserve pool”. Pumping later resumed when alternative supplies connected

(c)17 March: 4 helicopter drops of seawater on to reactor roof (approx 13.5 tonnes each: 54 tonnes total).

(d)17 March: riot police water cannon spray water onto Reactor roof

(e)18 March: six fire engines pumping seawater (flow rate 54 tonnes per hour) but duration of this work not reported

(f)22 March: estimated that 3,742 tonnes of ECW used to date

(g)25 March: TEPCO report that reactor vessel probably breached and leaking rad’ mat’s

(h)15^th May TEPCO report that Reactor 3 likely to be breached and leaking water

(i) August: ECW pumping still continues

4.2 As of yet I have not been able to access details of the flow rates of ECW pumping flow rates for Reactor 3.

Nor have I have been unable to find any comprehensive assessment of total volumes of ECW use re Reactor 3. Such data appears to have not been calculated.

4.3 However, the scant available details of the progress of events at Reactor 3 imply that pumping flow rates for ECW were, at the very least, broadly similar to those at Reactor 1.

But it should not be forgotten that there was an additional ECW strategy employed at Reactor 3, this being the application (by helicopter, water cannon and fire engine) of ECW to the reactor 3 roof at various rates (54 tonnes per hour) and (54 tonnes during 4 helicopter drops)

4.4 Therefore, and subject to the release of additional information, I propose that the range of Total Pumped Volume of ECW for reactor 3, be taken as similar to that of Reactor 1.

4.5 Total pumped ECW values for period 13 March to 23 Aug (163 days) thus range between

value a: 39,688 tonnes +1,224 tonnes = 40,912 tonnes

(average daily rate = 251 tonnes)

value b: 13,408tonnes +1,224 tonnes = 14,632 tonnes

(average daily rate = 90 tonnes)

BUT not forgetting the above mentioned (para 4.3) ECW applications to the Reactor 3 roof.

4.6 There has now been 164 days of continuous pumping of ECW through the reactor core. In the context of the

(a)official confirmation of meltdown beginning within five hours of the first earthquake because of cooling failure;

(b)constant application of ECW to reactor core; and

(c)`confirmation of leaks in the reactor pressure vessel and containment systems

It cannot be denied that ECW has been continuously passing over/through the reactor core (and subsequently the molten mass of fuel arising as a result of the meltdown) for 5..5 months and flushing a range of particulate and dissolved radioactive fission and activation products from the reactor core and into non-core, non pressure vessel and non-containment system environments: ie transporting those various radioactive materials from within a supposedly safe and shielded environment to the outside environment.

4.7 When reactor core cooling fails in such a situation the zirconium alloy fuel cladding fails and fission products are released. There can be no doubt that the ECW flows will have collected a highly significant quantity of the full range of fission products and transported them in the ECW flow through the reactor core, the pressure vessel, the containment buildings to whatever their end deposition site will have been.

4.8 No comprehensive calculation, assessment or estimate of the total volume/quantity of core derived fission products entrained in the ECW through flow has yet been made public.

Additionally such assessments for Reactor 3 are complicated by the fact the fuel was PU MOX.

4.9 In the absence of any other data it may be assumed that the full inventory of fission products derived from uranium oxide based fuels undergoing a meltdown were available for entrainment into the ECW deployed at Unit 3.

These fission products will have included approximately 17 actinides composed of:

Several isotopes of Uranium;

Several isotopes of Plutonium;

Several isotopes of Americium; and

Several isotopes of Curium.

4.10 However, there is a wide consensus that the higher Plutonium proportion in MOX fuel increases the amount of fission product and actinide created during combustion: in particular the “activity” of fission product/actinide arisings will be greater than that of normal Uranium based fuels

4.11 In addition the BWR cores will have contained isotopes of Caesium, Iodine, Tritium, and Rubidium and a cocktail of approximately 55 other radioactive isotopes (including corrosion products derived from the irradiation of reactor and pipe work structural materials as well as from the fuel and it’s cladding.) Such products will also be created as a result of MOX combustion.

5. Estimating the total volume of ECW used to date during reactor cooling

5.1 As a result of chaotic, spontaneous attempts to acquire and apply ECW during the response to unforeseen major events such an estimate cannot currently (and very probably never will) be accurately calculated.

5.2 Various press statements released by TEPCO have thrown a little light on the volumes of contaminated water released from the site.

On 21 April TEPCO estimated that 520 tonnes of radioactive water from Unit 2 had leaked into the sea via leaking “pits” before the leaks were plugged

Somewhat later TEPCO stated that 300,000 tonnes of “less radioactive water” leaked (or were deliberately released) in order to free up room for the storage of even more highly contaminated waters.

TEPCO have also described failed attempts to contain contaminated water in the harbour near the plant, by installing “curtains” to prevent outflow.

5.3 However, for one reactor specific response action (Reactor 1) there appears to have been at least an attempt to maintain an estimate of the flow rate of ECW being applied to the reactor core. This has allowed an estimated “range” of total volumes of ECW applied to Reactor 1 to be drawn up.

5.4 As demonstrated above this allows a range of daily ECW application to be estimated (for the period early March to late August) at between 90 tonnes per day and 250 tonnes per day per reactor.

5.5 Allowing for ECW application to 3 Reactors over a 164 day period (13 March to 23 August) we can calculate that the range of total ECW application for the period was between 44,190 tonnes and 122,750 tonnes.

5.6 However this is strictly dependant on the

(a)reliability of the flow rate figures given by TEPCO for the Reactor 1 ECW;

(b)the reliability of assumptions that the ECW flow rate for the other 2 reactors is broadly similar to that of Reactor 1; and

(c)the reliability of chronological details of ECW application provided by TEPCO.

5.7 However, as discussed earlier at 1:1 above, there is now a maturing and ongoing consensus among industry commentators that the Fukushima events have been characterised by

(a)low standard of accuracy and transparency of reporting;

(b)confusion of chronology; and

(c)confusion of factual detail (mistakes).

6. Spent Fuel Cooling Ponds: damage and remedial actions

6.1 Reporting of Spent Fuel Cooling Pond (SFCP) response is at least as confused and lacking in detail as is that for Reactor actions, possibly more so.

There does seem to be a consensus that

(a)the SFCPs, which sit above the reactors within the Unit buildings, are now without any form of containment since explosions have torn away their roofs and exposed the fuels to open air; and

(b)the SFCP at Units 1, 2 and 3 at least, had lost their cooling systems.

6.2 Unit 1 SFCP

31 March onwards: additional sea water added to spent fuel pond using concrete pump

14 May: freshwater replaces sea water use

29 May: freshwater injection via temporary pump and SFCP line

10 Aug: freshwater via circulatory SFCP line with heat exchangers

No flow rate data is provided for the volume of ECW used at Unit 1 SFCP.

6.3 No information is offered to clarify if the additional sea water added from 31 March was to

(a)replace water which had evaporated due to residual heat of spent fuels

(b)replace water which was leaking due to damage of pond structure

(c)replace water lost during an explosion scenario

6.4 The available scant information implies that injection pumping was continuous until August 10 when the circulatory SFCP lines with heat exchanger were finally deployed.

It may therefore be assumed (in the absence of any information to the contrary) that there were either leaks in the ponds or relatively rapid evaporation of pond water, requiring constant application of ECW until Aug 10 because prior to that date there is no mention of any circulatory cooling mechanism such as the heat exchangers.

6.5 Lack of detailed flow rate information means that at this stage absolutely no assessment can be made of the volume of Unit 1 SFCP water lost to the environment as steam or leaked water

6.6 Unit 2 SFCP

20 March onward: seawater added to spent fuel pond cooling line

29 March: seawater substituted for seawater

31 May: freshwater via circulatory SFCP line with heat exchanger

6.7 Once again no flow rate data was provided for the volume of ECW used in the Unit 2 SFCP.

No information is offered to clarify if the additional sea water added from 31^st March was to

(a)replace water which had evaporated due to residual heat of spent fuels

(b)replace water which was leaking due to damage of pond structure

(c)replace water lost during an explosion scenario

Thus the comments made in para’s 6:4 and 6:5 above apply in the case of Unit 2

6.8 Unit 3 SFCP

14 March: Water believed boiling away from SFCP (note this pond holding PU MOX assemblies which are thermally hotter than uranium fuel assemblies)

24 March: 35 tonnes of seawater added to pond via cooling system

25 June: 90 tonnes of “borated water” pumped into SFCP

2 July, water now injected into SFCP via circulatory cooling system with heat exchangers.

6.9 No information is offered to clarify if the additional sea water added from 24 March was to

(a)replace water, which had evaporated due to residual heat of spent fuels

(b)replace water, which was leaking due to damage of pond structure

(c)replace water lost during an explosion scenario

As was the case with the other units, no flow rate data was provided for the volume of ECW used in the Unit 3 SFCP.

Thus the comments made in para’s 6:4 and 6:5 above also apply in the case of Unit 3.

6.10 However, in the context of the need to respond to the elevated thermal heat of PU MOX fuel in the Unit 3 SFCP, it can be seen that the addition of 90 tonnes of borated water was required. This was not reported for Units 1 and 2.

6.11 In the context of that elevated thermal output, it appears probable that the basic cooling requirements of Unit 3 SFCP were greater than those of the other two SFCPs and thus a greater volume of ECW was required.

6.12 In summary it can be seen that

(a) there was a consensus that the SFCPs for Units 1,2 and 3 had all lost their cooling water systems

(b) the SFCPs at Units 1,2 and 3 were all in receipt of ECW,

(c) no data has been provided for the loss rate of cooling water in the ponds due leaks or evaporation

(d) no data has been provided for the flow rates of ECW application at any of the three SFCPs

7. Explosion at SFCP Unit 3?

7.1 Various sources continue to argue that the SFCP for Unit 3 (where the reactor was burning PU MOX fuels) had suffered some sort of explosion, which had ejected highly radioactive material to the outside environment.

7.2 In early April, the New York Times published details of a Nuclear Regulatory Commission assessment of the status of the Fukushima Daiichi plant. (“US Sees Array of New Threats at Japan’s Nuclear Plant”: by James Glanz and William J Broad).

It is this NRC assessment which suggests that fragments or particles of nuclear fuel from spent fuel pools above the reactors were blown “up to one mile from the units” and that pieces of highly radioactive material fell between 2 units and had to be bulldozed over to protect workers.

The NYT article also reported that the ejection of this material may indicate more extensive damage to the highly radioactive SFCP than previously disclosed.

7.4 “American nuclear engineer Arnold Gundersen, noting the much greater power and vertical debris ejection compared to the Unit 1 hydrogen blast, has theorized that the Unit 3 explosion involved a prompt criticality in the spent fuel pool material, triggered by the mechanical disruption of an initial, smaller hydrogen gas explosion in the building. Low-dose radiation researcher and anti-nuclear activist Christopher Busby speculated on Russia Today that the explosion that destroyed the Reactor 3 building was a “nuclear explosion” of some kind in the spent fuel pool.” (from Wikipedia: The Fukushima Nuclear Disaster)

7.5 Fairewinds Associates reported August 26^th that the very high Caesium 137 and 134 levels reported by TEPCO (19 and 20 August) following the analysis of SFCPs (Units 1, 2 and 3) water is evidence of spent fuel damage and confirms that the source of the spent fuel fragments found a mile from the Units was indeed spent fuel. from one or other of the SFCPs.

7.6 Whatever the cause of the explosion and subsequent ejection of highly radioactive material, there is no doubt that there is agreement that the event was of sufficient force to carry the highly radioactive material for “up to a mile” before deposition.

7.7 Evidently this scenario would have permitted the deposition of such material directly into the marine environment.

8. Marine Environmental outcomes of Fukushima events.

8.1 The major monitoring/analytical effort has focussed on the detection of radioactive Iodine and Caesium.

Radiological analysis of sea water by TEPCO, Greenpeace International and Japanese Government Agencies has proved the presence of very highly elevated concentrations of radioactive Iodine, 2 isotopes of Caesium, in seawater, seaweed and marine fish within a 30 to 50 mile radius of the Fukushima site.

8.2 A range of less well know and lower profile radioactive materials have also been analysed for (and found) in seawater: they are isotopes of

tellurium, technetium, chlorine, barium and lanthanum (March 29^th). Analysis for these items is at a much lower level than that for Iodine and Caesium.

Other nuclides have been identified in contaminated water (derived from reactor/SFCP leaks and ECW) found in basements and trenches attached to various reactor units; Thus in the basement of Unit 1 (25 March) TEPCO recorded the presence of isotopes of chlorine, arsenic, yttrium, iodine, lanthanum and three isotopes of caesium.

8.3 Direct deposition of “explosion ejected” radioactive debris into adjacent marine environment appears to be highly likely in the context of issues discussed in paras 7.1 to 7.7 above.

TEPCO have stated that small traces of Plutonium have been identified in five soil samples near Reactors 1, 2 and 3. TEPCO have agreed that the Plutonium in two of the samples is confirmed as “direct result of the recent incident”.

TEPCO have also reported that some of those soil samples also contain Curium 242, which supports the proposal that the Fukushima accident has indeed ejected alpha emitting actinides (from at least one of the reactors or SFCPs) into the site environment.

8.4 I have not found any statement giving details of the pathway of transport by which Plutonium and Curium was ejected from within contained structures.

Thus it remains an open question as to whether the Plutonium and Cm found and analysed by TEPCO was carried out of containment as a result of explosion followed by atmospheric discharge or whether it was carried out of containment in cooling water or ECW flows.

As of yet there is no evidence to support or reject either theoretical pathway and so the aquatic pathway remains a viable potential transport pathway for the Plutonium and Curium.

8.5 It is highly noteworthy that none of the actinides or recognised major alpha emitters, expected to be found inside the reactors and SFCPs, have been reported as analysed for in any marine samples (seawater, marine algae of marine fish) by any industrial or governmental agency.

No explanation has been given for this omission.

8.6 Entry of radioactive water (from within the Fukushima site) into the marine environment has been confirmed by TEPCO and other observers/commentators. Given the admitted earthquake damage to reactor containment and SFCP containment there can be no doubt that a percentage of that radioactivity is derived directly from the cooling waters from both sources PRIOR to the post-accident response injection of ECW to reactors and ponds.

8.7 Further radioactive contamination of the marine environment will inevitably have been caused by the remedial (post accident) inputs of ECW injected into leaking reactors and ponds

8.8 I have found no statement to the effect that radioactive waters from within the site have ceased to enter the marine environment. It must therefore be assumed that, at the time of writing this submission, the site radioactive run off continues to enter the marine environment

8.9 Official monitoring of radioactivity in terrestrial and atmospheric environments confirms that a reportedly large, but unquantified total amount, of radioactivity has been injected into the atmosphere and subsequently deposited via fallout and washout, onto terrestrial surfaces over a wide swathe of Japan.

There has been no indication that atmospheric leaks from within the Fukushima site have ceased, so it remains the case that radioactive fallout from the accident site continues to fallout and wash out onto land surfaces from which they can wash or leach into watercourses and hence to the marine environment.

8.10 The meteorological data demonstrates that winds have blown from many opposing compass directions since the initialisation of the accident. Thus, it is reported that during the first week of the accident winds blew from the west, thus taking (and depositing) most of the atmospheric releases seaward.

At other times since the earthquake/tsunami winds have blown radioactive atmospheric releases inland or seaward.

Plainly there has been ample opportunity for significant percentages of the atmospheric releases to be deposited onto the sea at varying distances from shore.

8.11 A number of media reports confirm that the Japanese authorities are aware that many standing (non-marine) waters have been contaminated by radioactive fallout and washout (eg: public and school swimming pools) and that these cannot be emptied and their contents disposed of as radioactive wastes because of lack of appropriate disposal sites and infrastructure.

8.12 The deposition of Fukushima accident derived radioactivity onto terrestrial surfaces means that under a variety of meteorological conditions (rainfall, snow melt, re-suspension of radioactive small particles in dry weather etc) such material will be remobilised to enter the marine environment by means of a range of mechanisms including

(a)leaching/remobilisation into rivers and streams running down to sea; and

(b)aerial mobilisation leading to “secondary” deposition to sea.

8.13 In the context of the atmospheric discharges and subsequent fallout of radioactive contamination onto land surfaces, it should be noted that, due to the meteorological fluxes described in the preceding paragraph, Fukushima derived radioactivity has now crossed the coastal watershed and fallen onto land and water surfaces from which watercourses are running westward, rather than eastward into the Pacific.

Thus, in the longer time scale, Fukushima derived radioactivity will be transported into the relatively enclosed Sea of Japan and impact upon coastal and estuarine environments there.

9. Immediate behaviour of ex-containment cooling waters and ECW

9.1 As described earlier, throughput of ECW through damaged reactor cores and damaged SFCPs must have transported a (so far un-quantified) percentage of that standard Uranium fuelled BWR isotopic inventory + the additional elevated concentrations of fission and actinide arisings from the MOX fuel

(a)out of the reactor core or cooling pond containment systems;

(b)into the immediate exterior environment of the Unit sites, (ie outside the containment buildings); and

(c)and then, as a result of continuing and expanding volumetric flow, further away from the Unit sites and out into the wider environment, where as liquid always does it will have gravitated towards the lowest possible physical level such as drainage systems, trenches, pits, canals, streams/rivers and the sea.

9.2 A study of the available, very poor description of the physical events and their chronology strongly implies that the process outlined above must have occurred in two stages.

9.3 Stage 1 must have consisted of the initial surge of very highly contaminated reactor and SFCP coolant, which would have leaked as soon as physical breaches (holes/leaks etc) of reactor containment vessels and SFCPs were created.

The volumes of such coolant remain unknown due to the lack of data about the volumes of steam and explosive hydrogen generated following the failure of reactor and SFCP cooling systems. This phase was relatively short lived by comparison to the second phase

9.4 Phase 2 consisted of the chronologically much longer term flow of ECW applied to reactor cores and SFCPs (still continuing through August as this submission is written) following the leaks/water loss associated with the initial incidents.

Within phase 2 there were evidently a series of “pulses” due to various technical failures and management decisions regarding the use of different pumping/ECW application techniques and equipment as set out in earlier paras above.

9.5 It is inevitable that these various surges and pulses will have exercised some significant modifying influences on the speed/direction, behaviour and end fate/destination of the highly contaminated radioactive waters under discussion.

However, these cannot be quantified as the events in question are over and done and no observations were made.

9.6 What percentage of this “escaped” liquid radioactivity may have reached the marine environment is un-quantified at this time and is almost certainly going to remain precisely un-calculable due to the lack of useful basic data already alluded to in many places above.

9.7 The relative radiological significance (concentration of radioactivity) of the Phase 1 leaked material compared to that of the Phase 2 leaked material can not be assessed in the current absence of relevant data.

However, the fact that Phase 2 leakage from the reactor cores includes ECW which has been poured over and run through the molten mass of the melted fuel in Reactors 1,2 and 3 and the SFCP at Unit 3 offers the possibility that the cumulative radiological impact of the Phase 2 ECW may be higher than that of the Phase 1 initial loss of coolant from reactors and SFCPs.

10. Fukushima Site Drainage System

10.1 Although a few, very basic, diagrams of parts of the site drainage system have been made public, these are

(a)universally highly simplistic and lacking in detail

(b)focussed on reactor units and turbine halls and associated basements and trenches

(c)fail to describe standard infrastructure across the rest of the Fukushima sites such as those designed to respond to normal site drainage issues such as rainwater

(d)fail to describe any additional emergency drainage infrastructure across the Fukushima sites such as those designed to deal with “planned for” emergency flooding scenarios such as excess rainfall

(e)fail to describe emergency drainage infrastructure across the rest of the Fukushima sites, specifically designed to deal with leaked reactor and SFCP coolant and/or other radioactive contaminated liquids

(f) fail to provide any detail of the volume of liquid which may be held within such basements or trenches, nor of the potential flow rate of liquid entering, running through or exiting such basements or trenches

(g)do not discuss emergency systems that may have been fitted to the drainage systems either to restrict excess flow or to hold/store excess flow. (All the available evidence strongly implies that no such emergency storage facilities existed.)

However, from the available diagrams and information it would appear that, in general, the Fukushima site drainage system does not differ markedly from that of any other nuclear power station.

10.2 Statements issued by TEPCO and Japanese Government agencies have only referenced 2 routes by which contaminated water from within the site has reached the sea, they are:

(a)as a result of deliberate discharge of pre-incident contaminated waters in order to make space in holding tanks etc for more highly radioactive waters arising as a result of the accident; and

(b)the overflow/escape of some radioactive water from the “trenches” and “pits” associated with Unit buildings.

It is hard to reconcile these confirmed leaks with the enormous quantities of ex-containment radioactive water reported to have been generated as a result of ex-containment cooling waters and the subsequent use of ECW.

10.3 I have been unable to access charts/maps/ground plans of the Fukushima site drainage system, in particular for those areas outside the reactor containment and SFCP buildings.

I have also been unable to access any information on the drainage flow rate of such site infrastructure.

I have been unable to access any data about whether any radiological analytical or monitoring equipment was installed/attached to any of the Fukushima site drainage infrastructure.

10.4 I have not found any reportage or discussion of the effect of either the earthquake, or the tsunami, on the integrity of any such site drainage infrastructure as may have been in existence prior to the events.

10.5 Despite the lack of such detail noted in 10:4 above, it may be concluded that (as is the case with other severe flooding events) the site drainage system was probably overwhelmed by the tsunami.

Thus, blocking of drainage channels and pipelines and their entrances and exits with debris, lifting/removal of man hole covers etc as a result of pressures forces, physical destruction of various infrastructure installation (reservoir walls, bunding, pumping equipment etc) has certainly occurred given the scale of both earthquakes and tsunami.

10.5 I therefore conclude that gravitational flow across the least impeded surface routes will have been the route by which the majority of the radioactive coolant and ECW will have entered the marine environment.

No evidence is offered to prove that this was not the case.

Reportage of the issue of pits and trenches should not be allowed to obscure this fact.

11. Attempts to assess the radiological significance of marine radioactivity

11.1 Quantitative clarification of the amount and significance of radioactivity likely to have entered the sea and it’s environmental impact has not been completed and cannot be so done until such time as thorough monitoring and analysis of ALL potential isotopes discharged is undertaken.

This work requires both a thorough examination of the melted fuels in Reactors 1,2 and 3 and the damaged fuels in the SFCPs and also a comprehensive analytical monitoring programme of a wide range of environmental media (terrestrial, atmospheric and marine) for a wide range of representative radioactive substances.

At the time of writing this submission no proposal for the above work has been identified

11.2 Focus on Iodine and Caesium isotopes is not sufficient, nor representative of the range of radioactivity discharged into the environment, and will not provide a full suite of data useful for the calculation/assessment of public health, environmental and commercial impacts because it fails to address the impacts of the other radioactive material released during the incident, especially that of the actinides/alpha emitters.

11.3 Various marine environmental sampling programmes have been undertaken by TEPCO, Japanese government agencies and environmental groups but these have all been characterised by

(a)a very narrow range of nuclides/isotopes analysed for

(b)an apparent poor understanding of short, mid and long term behaviour of radioactivity in the marine environment

(c)a very restricted geographical range of sample sites

(d)a very restricted range of environmental parameters subjected to analysis

11.4 Narrow range of nuclides/isotopes:

As explained in section 8 above, the main focus of the analytical work has concentrated on Iodine and Caesium isotopes

As indicated above (paras 2:7 to 2:10) a large number of fission products, actinides and other isotopes will have been present in side the BWR cores of Units 1 to 3 and the used BWR fuel assemblies stored in SFCPs. Additionally high levels of actinides will have been present in the MOX fuel in Reactor 3 and SFCP 3.

11.5 The fuel assemblies of the MOX fuels from reactor 3 and SFCP 3 will contain elevated concentrations of fission product and actinide created during combustion: in particular the “activity” of fission product/actinide arisings will be greater than that of normal Uranium based fuels (see para 4:10 above).

11.6 Despite the “in-site” discovery of both Plutonium and Curium, confirmed as having originated from within the site, and being a “direct result of the recent incident” and well understood to be present in reactor cores and SFCPs, (especially those containing MOX fuels) none of the range of alpha emitters/actinides known to be present in both reactor cores and SFCPs are reported as having been analysed for in any marine samples.

12. Poor understanding of behaviour of radioactivity in marine environments

12.1 Some nuclides such as the isotopes of Caesium and Iodine are highly soluble and dissolve relatively easily in NPP cooling water and in seawater

Highly soluble nuclides become well distributed through the water body and concentrations generally appear to dilute with distance from source. However, a few minor pathways of re-concentration do exist: thus Cs concentrations can be shown to be enhanced through marine food chains relative to sea water concentrations and indeed through coastal zone foodstuffs (impacted by sea spray and marine aerosols) relative to adjacent ambient sea water concentrations.

(See Appendix 1: relevant headings)

12.2 Irish Sea Caesium isotopes, derived from Sellafield liquid discharges to sea, have been found up to 10 kms inland in (south Wales) in pasture grass (having transferred from the sea to the land) and hence available for entry in to the dairy and meat food chains

Irish Sea caesiums from Sellafield liquid discharges have been found in the entirety of Hebridean island local food production (with highest CS doses received by terrestrial produce eater who did not eat fish). See Appendix 1.

12.3 These two examples provide evidence of both sea to land transfer and dietary doses at DISTANCE from discharge point.

(See Appendix 1)

N.B. In the context of these terrestrial doses it is evident that there’s a potential for inhalation doses of Cs and Iodine, both from sea spray, marine aerosols and evaporation from coastal mud flats.

12.4 I have no doubt that populations resident along the Pacific coast of Japan are currently, and will be for some time in the future, exposed to doses of highly soluble isotopes (derived from the Fukushima accident) transferring from the marine to the terrestrial environment by way of the mechanisms described above. Such exposure will give rise to doses of radioactivity via a number of pathways including ingestion of contaminated locally grown/gathered terrestrial foodstuffs, ingestion of locally grown/gathered marine foodstuffs and inhalation.

12.5 In the context of both the very high levels of soluble radioactivity expected to be discharged throughout the incident and the demonstrated ability of soluble radioactivity to travel for long distances from input source, the failure to conduct radiological mid field and far field monitoring and analytical work has been a major failure in both public protection and the gathering of scientific data.

12.6 Other nuclides have a low solubility and tend to be adsorbed onto the surface of particulate matter suspended in the water column. These sediments will in time settle and accumulate in sedimentary deposits such as inter tidal and estuarine mud flats: fine sediment, with their larger surface area, will accumulate more than coarse sediments : thus muds will have far higher concentrations than sands.

12.7 Many actinides and alpha emitters are preferential adsorbers.

Thus, Irish Sea Plutonium and Americium isotopes discharged from Sellafield are shown to become Adsorbed to fine sediment particles suspended in coastal water columns, and (in this form) enriched in marine micro layers relative to bulk seawater by factors of about 4. (Appendix 1)

12.8 Plutonium and Am are shown to become enriched (still in the adsorbed to particulate form) in marine aerosols (generated by bursting bubbles) by factors ranging up to 600 relative to bulk seawater. These aerosols are airborne and readily cross the surf zone and penetrate inland having. Such enrichment mechanisms are found in the context of relatively high sedimentary (fine) particle loadings of the ambient water column. (Appendix 1)

12.9 Such “adsorbing” actinides are also highly susceptible to re concentration in fine sediment deposits, thus, even at distance from input source, they may be found (in mud flats, river estuaries etc) at concentrations several hundred times higher than those observed in ambient sea water samples. (see Appendix 1: relevant headings)

12.10 Such mud flats may provide a source of readily air mobile fine sediments (in drying conditions with high winds) contaminated with adsorbed, and elevated concentrations, of actinides. Such conditions offer the potential for additional sea to land transfer of actinides.

13 Restricted range of marine sample sites

13.1 The various descriptions of marine monitoring efforts make it plain that they are focussed on the fate and behaviour of radioactivity within a relatively “near field” range of the Fukushima site liquid discharge point source: ie no further than up to some 30/40 miles radius distant from the discharge point source.

13.2 Results from this work have been fairly widely publicised and some commentators have noted the declining levels of concentrations of (mainly Iodine and Caesium isotopes) within the specific area and claimed that they demonstrate a positive environmental development.

13.3 I can report that satellite imagery of the Pacific coast of Japan (Fukushima Prefecture) shows an area of relatively shallow and turbid (high suspended sediment load) water extending off shore for about 1 to 2 kms/along the relevant stretch of coast

13.4 I note the presence of a number of rivers running down off the high ground inland, across the relatively narrow coastal plain and into the sea. I postulate that (in the wet season) these rivers will make a fairly high fine sediment (clay and organic mineral) contribution to the coastal water sediment budget.

Such sediments are particularly prone to the Adsorbtion of actinides

13.5 I’ve not yet accessed data about the local/regional inshore currents along that stretch of coast. However I can confirm that the general annual near-surface water body movement along the Pacific coast of Japan (Kuro Shio current) trends northwards

13.6 Satellite imagery of the relevant coast also shows the presence of some significant embayments 50 kms + to the north of the Daiichi plant outfalls.

Both Matsushima Bay and Ishinomaki Bay are extensive and appear (from visual my inspection of satellite imagery) to be characterised by high sediment loadings and extensive inter tidal sediment deposits.

13.7 Such environments have the potential to be long term deposition sites for any long lived actinide/alpha emitter present in the northerly moving water column environment, and hence to act as potential sources of (Fukushima accident derived) alpha emitting isotopes transferring from the sea to the land.

Should this be the case then those coastal zone populations resident adjacent to such environments may be exposed to such material by a number of pathways including ingestion of contaminated locally grown/gathered terrestrial foodstuffs, ingestion of locally grown/gathered marine foodstuffs and inhalation.

13.7 It’s my conclusion that the official monitoring regime being carried out by TEPCO and others is inadequate to the task of identifying the potential radiobiological threats to the public because:

(a)they are under-measuring both in terms of nuclides and isotopes because they have chosen to focus on relatively short lived Caesium and Iodine and ignored the issue of the alpha emitting actinides (some of which: including plutonium, americium and curium isotopes have half lives extending into the 1,000s of years) which must also be present in the environment.

(b)they over represent the issue of dilution and dispersion in that they fail to take account of widely attested mechanisms of re-concentration in specific marine environments

(c)they under represent the issues of long distance transport, transfer from one environmental media to another and pathways of delivery to human populations

13.8 It’s also relevant to note that a severe storm surge event in Liverpool Bay (UK) caused heavy flooding of coastal town during the course of which large quantities of offshore and near-coastal marine sediments (historically contaminated with Sellafield derived alpha radioactivity) were carried into the town and deposited in the streets, gardens and houses. This material was heavily contaminated with actionable concentrations of man made radioactivity ( significant quantities of Americium were recorded). (See Appendix 1: relevant section|)

In the current context, it seems not impossible that such a scenario may unfold in the future along this seismic and tsunami susceptible coast, and return a percentage of Fukushima event discharged radioactivity back to the land

13.9 Any attempts to truly quantify the radiological impact of the Fukushima events will of course be restricted by the accuracy and scale of any historical (pre-event) baseline data which may have been gathered on the volume, quantity and isotopic make up of historical discharges from the site: ie

(a)the quantities of man made radioactivity that may have been present in the coastal muds as a result of pre-event discharges from Fukushima NPs? and

(b)just how much of that radioactivity came ashore with the Tsunami inundations?

14: Restricted range of environmental parameters subjected to analysis

14.1 As may be deduced from the discussion in the immediately preceding paragraphs, monitoring of radioactivity in non-living environmental parameters should certainly not be restricted to sea water alone.

Fine sedimentary (and indeed organic) particles suspended in the ambient near coastal water column should also be analysed for both soluble and soluble isotopes. Water samples should be filtered in order to better, or more completely, isolate the sedimentary matter. Both filtrate and solids should then be analysed for soluble and less soluble isotopes.

14.2 Such work would greatly assist the plotting of the movement of both soluble and non soluble isotopes and hence diagnosis of the movement and potential deposition sites of alpha/actinides.

14.3 Similarly, those fine sediment inter tidal, near shore and offshore deposition environments regarded as being downstream of the Fukushima marine radioactivity inputs require both identification and subsequent monitoring/analytical work to identify current and ongoing rates of deposition of potentially harmful concentrations of alpha/actinides and enable contingency planning and early warning systems to be put in place should any potential or actual mechanism for the transfer of such material from the marine to the terrestrial environment be identified or occur.

14.4 In the context of those well attested mechanisms of sea to land transfer shown to be contributing to the delivery of doses of marine radioactivity (via ingestion of terrestrial foodstuffs and no doubt inhalation) following sea to land transfer of man made radioactivity, there is a strong case for the monitoring and analysis of

(a)sea surface micro layers where preliminary concentrations of radioactivity build up prior to the production of marine aerosols;

(b)marine aerosols , especially those produced in the surf zone of sediment enriched coastal waters, where very high re-concentration factors have been observed; and

(c)sea spray droplets especially those coming ashore in onshore winds.

14.5 In the context of the list of occurrences at the Fukushima site (explosions, meltdowns, breaching of reactor containment, possible breaching of SFCP containment, massive loss of coolant, massive throughput of ECW) there are no scientific grounds for denying that actual “hot” particles of radioactive fuel, radioactive fuel cladding and possibly) SFCP structure have also entered the non-containment environments both within the site and outside the site.

14.6 There is absolutely no evidence that any of the marine monitoring programmes so far initiated are making any attempt to identify and quantify “hot” particles of radioactive fuel, reactor or SFCP structures.

15. Position statements from the Environment Agency GDA

15.1 In the event of

(a)Reactor or cooling pond LOCA event requiring the use of Fukushima type volumes of Emergency Cooling Water; and

(b)Severe flooding of sites (tidal bore, storm surge, tsunami, excessive rainfall (lets not forget the unusual path of Hurricane Katie).

The following extracts from the GDA are relevant:

GDA ASSESSMENT Report UK EPR-05

Assessment Report: Aqueous Radioactive Waste Disposal and Limits

Page 25: Para 118

EA say: We have not considered at GDA other site liquid discharges such as surface water. The design of such systems will be site specific and there should be no contamination in normal operation. We will review site drainage at site specific permitting and, as a minimum, require accessible sampling points at final discharge locations for confirmation spot sampling.”

Annex 1 (Fig 1) of the same document shows collection and management of three liquid effluent streams

(a)Primary Liquid Effluent.

(b) Spent Liquid Effluent.

(c)Drainage Water from Turbine Hall.

15.2 In their GDA Assessment Report AP1000 Assessment Report: Aqueous Radioactive Waste Disposal and Limits the Environment Agency list five sources of aqueous radioactive waste (Paras 35—46)

(a)Reactor Coolant System Effluents

(b)Building floor drains and sumps

(c)Detergent wastes (sinks, showers etc)

(d)Aqueous chemical wastes (laboratory and other small volume sources)

(e)Steam Generator blowdown wastes

15.3 And at Page 15: Para 49

EA say “ We consider that all sources of aqueous radioactive waste have been identified”.

15.4 And at Para 57 (page 16)

EA say “AP1000 has five types of tanks for collecting aqueous radioactive waste”

A:	Reactor Coolant drain tank	volume= 3.4 cubic metres
B:	Effluent Hold up tanks	volume= 2 x 106 cubic metres
C:	Waste hold up tanks	volume= 2 x 57 cubic metres
D:	Chemical waste tank	volume= 34 cubic metres
E:	Monitor tanks (42 days storage)	volume=6 x 57 cubic metre
TOTAL VOLUME		=705’4 cubic metres

15.6 It is evident that the information given in the GDA’s Aqueous Radioactive Assessment Reports is relevant to only “normal operations” .

The GDA Aqueous Radioactive Assessment Reports fail to address LOCA response and the potential for massive Emergency Cooling Water (ECW) arisings, and do not conduct an analysis of the potential damage to site infrastructure, storage tanks or drainage systems due to unforeseen circumstances.

The GDA Aqueous Radioactive Assessment Reports fail to address the issues surrounding the necessity for the provision of capture/retention/treatment capacity for hundreds of thousands of cubic metres of ECW generated over a six month (and ongoing) period

15.7 Thus, at Fukushima Daiichi, an unknown volume of ECW had already leaked into environment when TEPCO began to provide estimates of the volume of Emergency Cooling Water (ECW):

Sept 6 to 11 TEPCO press statements say that,

(a) since June, when filtering systems were finally installed, they have managed to decontaminate 85,000 tons of highly radioactive water (HRW)

(b)110,000 tons of HRW remains in basements of the reactor buildings 1,2 and 3.

(c)ECW still being applied daily to Reactors 1, 2 and 3

(d)Growing concern that basement HRW may be leaking into the sea via groundwater flows

(e)Concentrated nuclear waste generated by filtration treatment of 85,000 tons of HRW now occupies 70% of site dedicated, 800 cubic metre, waste storage capacity. (Waste generated so far thus equals 560 tonnes)

(f)TEPCO states need to review cooling efforts in light of the continuing ECW applications and nuclear waste generation

15.8 N.B.:

85,000 tons +110,000 tons= 195,000 tons captured/retained ECW (no calculation has been offered for volume lost to the environment)

85,000 tons HRW treated in 3 months = approx 1000 tons per day = thus it will require approx 110 days to clear the existing backlog (not counting ongoing applications of ECW)

Basements plainly acting as storage tanks

Fear of leaching of HRW

Evident that the nuclear waste produced by filtration treatment of remaining 110,000 tons of HRW (not including ongoing applications of ECW) is going to overwhelm site storage capacity.

15.9 Recommendations

Site drainage (with specific relevance to emergency situations including LOCA response and inundation) should be made a GDA issue and NOT be determined on a site specific basis.

The GDA should review reactor basement design and construction in order to confirm that, if they are to be used for collection and storage of spilled reactor and/or cooling pond coolant and ECW, they will prevent leaching, facilitate the monitoring of the HRW and escaped coolant and be provided with appropriate equipment such as pumps, gauges etc.

HRW capture/retention, storage and treatment capacity should be made a GDA issue and NOT be determined on a reactor specific or site specific basis. It should be thoroughly reviewed in the context of the Fukushima event

The storage capacity for highly concentrated wastes generated by the filtration treatment of HRW should be reviewed by the GDA with a view to ensuring that, in the event of the need to filter treat high volumes of escaped coolant and contaminated ECW, there is sufficient storage capacity for the ensuing highly concentrated radioactive waste

Tim Deere-Jones

FREELANCE MARINE POLLUTION CONSULTANT

CV, Client List & Work History

I have been working as a Marine Pollution Consultant since 1983.

Education

BSc. Hon’s (2:1) Maritime Geography, Department of Maritime Studies, Cardiff University, Wales, UK (Maritime Geography course designed to educate “marine managers”)

Core Studies: Marine Pollution, Marine Environmental Sciences, Ocean/Atmosphere Systems and Marine Anthropology.

Honours Research Dissertation: “The Sea to Land Transfer of Marine Pollutants”

Previous Clients include

Greenpeace International: Greenpeace Australia: Greenpeace UK: Friends of the Earth (England, Wales and Northern Ireland): Friends of the Earth Cymru: World Wide Fund for Nature (WWF UK): The UK Wildlife Trusts: Citizens Campaign Groups in UK, Irish Republic and USA: Local Authorities in England and Wales: UK and Irish Nuclear Free Local Authorities: KIMO: Global Concern.

For whom I have carried out a variety of desk study and fieldwork consultancy contracts relating to:

Anthropogenic marine radioactivity issues including both field and desk work on

Fate and behaviour of anthropogenic radioactivity in marine, coastal and inter-tidal environments: sea to land transfer of anthropogenic radioactivity across Irish Sea coastlines: fate, behaviour and inland penetration of sea to land transferring anthropogenic radioactivity and it’s impact on agricultural and horticultural produce

Maritime transport of hazardous and dangerous radioactive cargoes including:

Long term work on the safety of the maritime transport of radioactive wastes (LLW, ILW, HLW and Pu MOX): analysis of accident statistics and design flaws in hazardous and radioactive material carriers: loss of containerised deck cargo consignments of hazardous radioactive materials: detailed desk study reviews of design flaws in double hulled vessels (PNTL Fleet) carrying high level radioactive wastes.

Marine and Coastal oil and chemical spill issues including:

Fate and behaviour of spilled oil and chemicals in marine, coastal and inter-tidal environments: environmental impacts of spill treatment strategies: environmental impacts of transport and disposal of recovered contaminated debris: economic impacts of spills: impacts of spills on coastal zone agriculture: physical, psychological and emotional public health impacts of spills: effects of spills and remedial action on small coastal and island communities.

On behalf of Citizens Campaign Groups and others in the UK, Ireland, France, Australia and the United States I have also carried out work on:

Environmental impacts of ship breaking and decommissioning in an industrial estuary: Environmental and heritage impacts of tourism developments on coastal environments and communities: environmental impacts of port developments: environmental impacts of marine aggregate extractions in UK waters: environmental impacts of marine aggregate extractions in S.East Asia: environmental impacts of capital and maintenance dredging programmes: the impacts of industrial scale fisheries on small scale artisan fisheries: cetacean by catch in pair trawling fisheries: investigation of radioactivity and PCB tissue burdens in coastal cetaceans: investigation of local point sources of PCBs in the marine environment: causes and environmental impacts of localised coastal erosion.

Field Work

I have successfully planned and carried out field work campaigns in coastal environments in the UK, Ireland, France and the Irish Sea on issues including:

surveying and sampling estuarine intertidal sediments to establish the presence and distribution of anthropogenic radioactivity: surveying and sampling coastal and estuarine terrestrial soils and flora (lichens) in order to establish the presence of anthropogenic radioactivity: surveying and mapping the movement of surface floating radioactive “cruds” in the Irish Sea and the Bristol Channel: surveying small island and coastal environments to establish the presence and distribution of toxic heavy metals transferred from the sea to the land: observing and reporting the fate, behaviour and impact of spilled oil on a wide range of coastal environments.

I currently hold the posts of :

Marine Science Syllabus Consultant and Senior Examiner to the International Baccalaureate Organisation and

Honory consultant/advisor on marine radioactivity issues to the UK and Irish Nuclear Free Local Authorities

I have held honorary posts as:

(a)Research Director of the Irish Sea Project (independent and voluntary funded marine radioactivity research/campaign group) (6 years)

(b)Founding Co-ordinator of MARINET (Friends of the Earth: Marine Information Network) (3 years)

I participate (as a group leader and extra mural lecturer) in University undergraduate field visits to coastal environments.

I am an experienced environmental journalist, having written for a wide range of newspapers, magazines and journals including The Ecologist and the BBC Wildlife Magazine

I have made many contributions to TV and Radio news items, current affairs broadcasts and documentaries. I have made many presentations to conferences in the UK and Ireland (in the role of both conference guest speaker and leader of seminars and workshops) and have participated in Public Planning Inquiries in UK and the USA as consultant/expert witness on behalf of clients and as a representative of citizens groups and environmental campaigning organisations.

November 2012