Variation to Authorisations to dispose of Radioactive Waste from AWE Submission by the Nuclear Information Service to the Environment Agency Consultation
1. Alpha Discharge to air limits
The regulation of Alpha discharges to air needs to be transparent. An Authorised limit is needed by which to judge any excessive discharges due to a mistake or accident.
2. Tritium Discharge Limit for the Aldermaston Stream
The regulation of Tritium discharges to local watercourses needs to be transparent. An Authorised limit is needed, by which to judge any excessive discharges due to a mistake or accident.
3. The Effect of the Closure of the Pangbourne Pipeline
The closure of the Pangbourne Pipeline has been a forward step. However, other problems have been created, including the following:
i. additional discharges to air end up in rivers and on land
ii. additional liquid discharges go to the Thames via the Foundry Brook
iii. the pipe remains in an 18Km radioactive waste trench stretching across Berkshire.
AWE should be required to build and maintain additional storage ponds to retain more liquid on site to enable the radioactive content of liquid effluent to be further reduced before going to Silchester Sewage Works or to local watercourses.
The EA should prepare a consultation document on the issues for and against removal of the pipeline waste to the AWE site.
4. Landfill and Incineration
NIS shares the view of Environmental NGOs that all ILW, LLW and VLLW waste should be stored on site until its radioactivity has decayed. This applies to tritium-contaminated waste and Carbon-14 particularly, the later being completely unsafe for incineration. While the problem of storage space is accepted, resolving the problem on this extensive secure site remains AWE’s responsibility.
If the above principle is rejected by the EA, transparency should be introduced relating to contracts with companies prepared to take AWE radioactive waste for landfill or incineration. Communities local to incineration and landfill sites should be consulted at this Consultation stage, albeit that AWE contracts are not let and may not go to all sites listed as possibilities.
The solution of super-compaction to avoid incineration and to achieve the minimisation of space needed for storage of waste is an acceptable solution. However, in order to end road transport of waste, this process should be the responsibility of AWE on site. Such a plant would be a valuable asset and reduce costs and storage problems in the long term.
6. On-site Storage
AWE should be required to accommodate all its own solid and liquid waste on site. The storage of waste is a major responsibility for AWE now, and the task will grow in future. AWE should be prevented from pursuing its current objective to reduce the overall site footprint and return an area of land to common use. The opportunity presented by this new Authorisation should be taken by the EA to assess and legalise a system whereby waste remains in AWE’s own ‘back yard’ rather than be peddled round the country.