28th July 2006
AWE plc Review
Nuclear Regulation Group (South)
Red Kite House
Wallingford OX10 8BD
Consultation on Variation to Authorisations to dispose of Radioactive Waste from AWE
We submit the following comments from NAG Ltd:
Alpha discharges to air
We are pleased that these discharges are currently at a very low level. However, we are aware that this may not be a permanent state of affairs, and therefore suggest that limits for disposal of alpha emitters to air are retained for future radioactive waste disposal authorisations for AWE.
VLLW and Landfill
· We are concerned that disposal of VLLW waste to landfill would mean that it will disposed of under less than stringent conditions. The potential for Tritium to leach into groundwater has been demonstrated. The draft authorisation does not specify how this problem will be addressed.
· The new authorisation should specify that very low level radioactive waste from AWE can be disposed of at ‘suitably licensed’ landfills, rather than landfills in general.
· The new authorisation should specify the locations and license numbers of specific landfill sites at which such waste may be disposed of, in the same way as which the location of other disposal sites is identified in the proposed new authorisation.
· NAG is opposed in principle to the use of landfill for storage of radioactive waste. This is dispersal not disposal
- The revised authorisation issued to AWE by the Environment Agency should include an up-front statement that AWE should move towards a waste minimisation / zero waste approach to waste management on site, rather than end-of-pipe waste abatement. In due course AWE should provide the agency with a detailed programme for minimising waste by process improvements as part of its proposals for future developments at the site.
- The Environment Agency should set specific process improvement targets in future authorisations to ensure that this happens. Future authorisations should also specify that an annual report to the public on waste minimisation measures adopted at AWE should be prepared.
- We are glad that the Environment Agency accept that waste incineration, and in particular the incineration of waste contaminated with radioactive substances, is a controversial issue. In principle, the disposal of radioactively contaminated waste by incineration should not be considered good practice as it may result in the production of toxic combustion products as well as disperse radioactive materials to the area surrounding the incineration site.
- In particular, we believe that waste contaminated with isotopes which have a half-life well beyond human timeframes, such as Carbon-14, is not suitable for disposal by incineration.
- NAG does not support proposals to allow the disposal of radioactive waste from AWE by incineration. If, however, the Environment Agency intends to authorise disposal of radioactive waste from AWE by incineration, conditions should be included to prevent the disposal of all but short-lived isotopes by this route, and to require steps to be taken to ensure that waste sent for incineration does not include chlorinated plastics or organic compounds which can give rise to dioxins when incinerated.
- NAG does not support the transportation of radioactive waste for supercompaction to other sites when it can be done at AWE. We would like to see supercompaction on site to be made a condition
Storage of Radioactive waste
- While AWE have strategies for dealing with radioactive waste, they do not appear to have a medium to long term plan or the equivalent, which might give the public some concept of what the future holds in terms of living near a radioactive waste store and indicate to regulators and others the quantities and types of radioactive waste which are likely to arise from activities at the site over the years ahead.
- AWE should therefore prepare a 5 year waste disposal plan which should be available to the public.
- The new authorisation for the site should specify upper limits for waste holdings which can be retained on site.
Transport of radioactive waste
- The authorisation should specify that contractors carrying waste from the site should be licensed carriers. Appropriate safety conditions should be specified.
- The Environment Agency should consider whether closer internal liaison between teams responsible for the regulation of radioactive substances and teams responsible for waste disposal would be advantageous in ensuring an appropriate regulatory regime for waste arising from AWE.
Operation of waste disposal plant
· Waste disposal operations and plant should at all times be operated and attended by suitably qualified and experienced personnel.
· AWE should prepare a quantitative report on a quarterly basis on waste disposal issues and compliance with authorisations which should be available to the public and posted on the company website.
- We find it a matter of public concern that West Berks Council Planning Committee passed the plans for the Laser in the belief that there were no radioactive implications, while both AWE and the Environment Agency knew that this was not true.
- While accepting that the Tritium which continues to leak into Aldermaston Stream results from past activities on the site, we would ask for some indication of how long this is expected to go on? This is information which should be available for instance to anyone planning to move to Aldermaston Village.
- We do not agree that there is no benefit in setting an activity limit for this discharge. Public confidence would be harmed by dropping this limit in favour of an arrangement which relies too much on AWE’s honesty.
- It has been obvious for a considerable time that closure of the Pangbourne pipelines would involve the tritium going elsewhere. We now deduce from para 5.29.11 that the tritium is still going into the Thames, only via Foudry Brook, at levels above the WHO guidelines for drinking water. We draw your attention to the fact that local children have played and fished in the Foudry Brook since time immemorial, especially in hot weather such as we are experiencing at the moment . The Foudry does not carry large volumes of water to aid dilution, especially in hot weather. Requiring AWE to reduce the volume of liquid effluent going to Silchester does nothing to address this problem. It should have been addressed at the LETP planning stage and appears not to have been, and we are not confident that it is being adequately addressed now.
NAG Ltd is happy for this response to be published as part of any Environment Agency report on the consultation process for setting the new authorisation for disposal of radioactive waste from AWE.
(for NAG Ltd)