The Nuclear Free Local Authorities (NFLA) has recently submitted detailed research and its wider concern to the Environment Agency (EA) and Natural Resource Wales (NRW) over their Generic Design Assessment (GDA) of the environmental issues around the Advanced Boiling Water Reactor (ABWR) being proposed for the Wylfa site in Anglesey and the Oldbury site in Gloucestershire. (1)
The NFLA has commissioned independent marine radioactivity consultant Tim Deere-Jones to analyse the EA / NRW joint consultation seeking views on the environmental information provided by Horizon Nuclear, the Hitachi-owned company developing the ABWR design for Wylfa and Oldbury.
The NFLA submission focuses on issues around proposed spent fuel cooling points, issues around potential leaks from the reactor, aqueous radioactive discharges into the marine environment and concerns over plutonium and tritium. The comparisons between the Fukushima BWR design and the ABWR are also highlighted in significant detail.
Key conclusions of the NFLA submission include:
- The GDA assessment of aqueous radioactive waste Issues is incomplete and does not provide a detailed analysis of relevant issues, sufficient to assess the potential inputs of radioactive wastes to UK marine environments and to assess the safety of spent fuel cooling ponds (SFCPs) under a terrorist attack or reactor accident scenarios.
- The NFLA is concerned that the design of the SFCPs of the proposed UK ABWR replicates those of the Fukushima reactors and that, to date, the GDA has not considered this issue.
- The NFLA has requested that the GDA process provide an estimate of the frequency of expected leaks, from both the precursor reactors which have operated in Japan, the proposed UK ABWRs and all other UK nuclear power stations.
- The NFLA has, so far, been unable to find details of any reactor that has not suffered leaks (to water and air) on an every year basis. The NFLA’s submission cites examples of prolonged leaks to sea from UK sites, with high aggregated radioactivity inputs to UK waters.
- The NFLA is concerned that the GDA does not discuss the input of radioactivity to UK marine environments derived from the ‘washout’ or ‘fallout’ of atmospherically discharged nuclear wastes from proposed UK ABWRs.
- The NFLA is concerned to note that the totality of constituent radionuclides in proposed aqueous radioactive waste discharges to sea is also not discussed in the GDA document.
- The NFLA is concerned that 13 alpha-emitting radionuclides have been omitted from the GDA tables. The NFLA notes that other nuclides also deemed “insignificant” in terms of their impact have been omitted, and that the source for the definition of insignificance is the Guidance Paper, Euratom/2004/2.
- The NFLA notes that Euratom/2004/02 does not report the most recent, and highly significant evidence relating to both the Organic Bonding of Tritium and the production of the very long-lived alpha emitter Americium-241, by decay of Plutonium-241, in the Irish Sea.
NFLA submitted its response recently to the Environment Agency and Natural Resource Wales, and Tim Deere-Jones presented these outline issues to the NFLA Welsh Forum meeting held in Aberystwyth.
NFLA Steering Committee Chair Councillor Ernie Galsworthy said:
This NFLA submission to the Environment Agency and Natural Resource Wales considers in great detail the potential environmental and radioactive discharge issues around the new nuclear reactors proposed for Wylfa and Oldbury. NFLA are concerned key omissions in information exist and they are not as confident as the regulators that the generic design assessment is being rigorous enough in accounting for important information. With no operating reactors of this type generating anywhere in the world NFLA are concerned that a leap into the unknown could take place that puts environmental and health risks onto the wider population. NFLA calls on a much more detailed assessment to be made before GDA approval is granted, as planned by the regulators, at the end of 2017”
Ends – for more information or an interview with Time Deere-Jones please contact Sean Morris, NFLA Secretary, on 0161 234 3244.
Notes for editors:
(1) The NFLA New Nuclear Monitor with its GDA response is attached with this media release and will go on the NFLA website http://www.nuclearpolicy.info.
(2) SUMMARY OF NFLA RESPONSE:
The NFLA has submitted a detailed Consultation Response to the Environment Agency/Natural Resources Wales Generic Design Assessment report AR05. The NFLA submission covers a number of issues it believes are of major significance, but which the GDA process has not addressed in an adequate manner.
The NFLA finds that the GDA assessment of Aqueous Radioactive Waste Issues is incomplete and does not provide a detailed analysis of relevant issues, sufficient to assess the potential inputs of radioactive wastes to UK marine environments and to assess the safety of Spent Fuel Cooling Ponds under terrorist attack or reactor accident scenarios.
a) Spent Fuel Cooling Ponds (SFCPs)
- The NFLA is concerned that the design of the SFCPs of the proposed UK ABWR replicates those of the Fukushima reactors and that, to date, the GDA document AR05 on aqueous wastes has not considered this issue.
- The NFLA notes that the Fukushima SFCPs were widely reported to have suffered a loss of both coolant water and structural integrity and that this failure was attributed to the fact that they were located at the very top of the reactor building (four stories above ground) outside the primary containment area of the reactor building, and clustered very closely around the actual top of the reactor itself.
- The NFLA is also concerned that the design and positioning of the SFCPs appears highly vulnerable to terrorist attack from the air or from mortar, RPG (or other explosive devices).
- The NFLA notes that ongoing reporting from Fukushima site confirms that breaches of containment at the SFCPs were a major factor in both the initial pollution of marine environments, and the subsequent ongoing pollution following the necessary application of thousands of gallons of emergency cooling water, through the leaking SFCPs, which could not be prevented from escaping to sea.
- The NFLA has therefore requested that the GDA process examine this issue in depth and report on the risks to SFCP integrity from both potential reactor accidents and terrorist attack.
b) Liquid waste discharges to sea from proposed UK ABWRs
- The NFLA is concerned that the GDA process review of aqueous waste discharge issues provides incomplete data on a range of issues as follows:
Leaks –
- The NFLA has, so far, been unable to find details of any reactor that has not suffered leaks (to water and air) on an every year basis. The NFLA’s submission cites examples of prolonged leaks to sea from UK sites, with high aggregated radioactivity inputs to UK waters.
- Noting the sixty year proposed operational lifetime of UK ABWRs, the NFLA is concerned that such leaks may, over such a prolonged working life, make considerable additional liquid radioactive waste inputs to UK marine environments.
- The NFLA is concerned that, in this context, the GDA document AR05 has not attempted to estimate the annual and lifetime leakage rate of UK ABWRs, or to offer estimates of the amount of radioactivity likely to enter UK marine environments by this route.
- The NFLA has therefore requested that the GDA process examine this issue in depth and provide an estimate of the frequency of expected leaks, from both the precursor ABWRs (which have operated in Japan), the proposed UK ABWRs and all other UK NPS.
- The NFLA has also requested the GDA process to examine and provide data on the expected annual and total lifetime aggregated radioactivity inputs to UK seas from leaks from the Japanese ABWRs, the proposed UK ABWRs and all other UK NPS
c) Inputs to UK seas from UK ABWR washout/fallout:
- The NFLA is concerned to note that GDA document AR05 has not discussed the input of radioactivity to UK marine environments derived from the washout/fallout of atmospherically discharged nuclear wastes from proposed UK ABWRs.
- The NFLA submission has briefly reviewed this issue and referenced the significant reported short term inputs made to UK marine environments by the washout/fallout of Chernobyl derived radioactivity.
- Noting the proposed 60 year operational lifespan of the UK ABWR (and also the fact that the majority of UK NPS have been granted operational lifespan extensions), the NFLA believes that the washout/fallout of UK ABWR atmospheric radioactive wastes may generate significant cumulative inputs of aggregated radioactivity to UK marine environments over operational lifespans.
- The NFLA also notes that proposed sites for UK ABWRs (Wylfa Newydd, Oldbury) appear well suited to high levels of washout/fallout of atmospherically discharged radioactivity due to locally high rainfall, prevailing winds and weather and regional topography.
- The NFLA has therefore requested that the GDA examine this issue in depth and provide an estimate of the quantity of aggregated, atmospherically discharged radioactivity (from both annual and lifetime operations of the UK ABWR), which is expected to be deposited to UK marine environments as a result of primary washout/fallout (i.e. direct to marine surfaces) and as a result of secondary washout/fallout (i.e. deposited on terrestrial surfaces and inland waters and subsequently “flushed “ into marine environments).
Totality of radionuclides discharged to sea:
- The NFLA is concerned to note that the totality of constituent radio nuclides in proposed aqueous radioactive waste discharges to sea is not discussed in GDA Document AR05.
- -The NFLA notes that Hitachi GDA submissions and the GDA Document, reference 35 radio nuclides expected to be discharged via liquid waste streams and is concerned that this reference mentions a much lower number of radio nuclides for discharge to sea than is the case at other NPS design proposed, or operating, in the UK (50+ nuclides)
- The NFLA notes that Hitachi and GDA documentation also reference Tables of “Assumed Annual Liquid Discharge Rate” from ABWRs for 24 radio nuclides, “Calculated Annual Liquid Discharge Rate” for 10 radio nuclides and an “Actual Measured Value” for liquid discharges from Japanese ABWR which only provides data on Tritium.
- The NFLA is concerned that the up to 13 alpha emitting nuclides have been omitted from these tables. The NFLA notes that other nuclides also deemed “insignificant” in terms of their impact have been omitted, and that the source for the definition of insignificance is the Guidance Paper, Euratom/2004/2.
- The NFLA notes that Euratom/2004/02 does not report the most recent, and highly significant evidence relating to both the Organic Bonding of Tritium and the production of the very long lived alpha emitter Americium 241 by decay of Pu 241 in the Irish Sea.
- The NFLA has therefore requested that the GDA examine these issues in depth and provide a full and precise list of ALL radio nuclides likely to be constituents of UK ABWR liquid discharges to sea, makes further attempts to acquire improved EMPIRICAL/ACTUAL data (i.e. not “Calculated or “Assumed”) for all radio nuclides and to respond to NFLA concerns on the issues of Am 241 production and Organically Bonded Tritium