This consultation Submission is in response to the ICRP Draft Document “ICRP 2019: Draft Document : Radiological Protection of People and the Environment in the Event of a Large Nuclear Accident” , which has been publicized for comment before 25th October: 2019.
The author of this Submission is Tim Deere-Jones, a marine pollution consultant with 30 years of work experience across the global ocean, with specific interest and work focus on marine oil spills and marine radioactivity issues.
The principal response of this Submission regarding the ICRP Draft Document is that the ICRP Draft has, by ignoring marine specific issues, and offering no specific proposals for the protection of people and marine environments from the consequences of a Large Nuclear Accident, has not provided an adequate response to concerns about the Radiological Protection of People and the Environment in the Event of a Large Nuclear Accident affecting marine environments.
The Submission introduces summary reviews of 3 case studies of marine environmental, radiological impacts following major LNAs, and catalogues and describes the flaws in the post event scientific investigation, as well as indicating the failure of dose assessments for coastal zone populations and marine stakeholders that have occurred due to the flawed investigative work.
Appendix 1 contains a summary of UK research addressing issues of the sea to land transfer of marine radioactivity.
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Contents:
Summary of main Submissions ……………………………………………………… page 2
Case studies:
1957 Windscale Fire ……………………………………………………………….. page 3
1986 Chernobyl event ……………………………………………………………… page 4
2011 Fukushima event …………………………………………………………….. page 8
Appendix I: Sea to land transfer briefing ………………………………………… page 13
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Summary of main submissions 1: This Submission notes that the ICRP Draft Document is 90+ pages long but that, despite the over whelming evidence of marine impacts of both the Chernobyl and the Fukushima events, it’s coverage of marine related issues has been awarded a mere 18 lines or 2 paragraphs .
2: This Submission contends that because the majority of the world’s nuclear sites are situated on the coast, or on waterways that eventually drain into marine environments, marine environments are specifically susceptible to major radiological pollution episodes following Large Nuclear Accidents (LNAs) and that such marine environments should therefore be provided with environment specific sampling, monitoring and analytical research programmes in the event of LNAs
3: This Submission contends that marine impacts on intermediate and far field marine/coastal environments from LNAs are inevitable due to the fact that many of the historical LNAs have involved the generation of relatively high altitude thermal plumes known to have injected both radioactive gases and particulates into the upper atmosphere and hence made them available for transport over significant distances prior to their eventual fallout/washout onto marine and terrestrial surfaces.
4: This Submission contends that marine impacts on near, intermediate and far field marine/coastal environments from LNAs are also inevitable due to the fact that a significant proportion of the historical LNAs have involved Loss of Coolant Accidents (LOCAs) leading to the escape of reactor and/or spent fuel cooling pond liquid coolants and the subsequent generation of marine radiological plumes of radioactive liquids and particulates available for transport over significant distances and subsequent deposition and re-concentration in marine, coastal and estuarine environments
5: This Submission contends that the historical research response to the impact of LNAs on marine environments is characterized by systemic weaknesses in the investigation of the behavior and fate of radioactive fallout in marine, coastal and estuarine environments, the impact on those environments and the impact on maritime and coastal zone populations in affected sea areas, and that the ICRP document under consideration presents a prime example of such systemic weakness because it does not address marine specific issues and offers no proposals
6|: This Submission contends that, despite the fact that the Chernobyl event has been shown to be the root cause of secondary, time delayed, contamination of distant sites following forest fires occurring many year after the original event, the ICRP Draft document offers no commentary on such an event and proposes no plan or action to respond to such an occurance.
7: This Submission contends that the repeated (post event) focus on short lived beta emitting nuclides combined with a refusal to investigate long lived alpha emitters is without proper scientific justification and represents a major failure of data collection leading to a major information “black hole”. The result of this “black hole” is that there is insufficient data about the impacts of LNAs on marine radioactivity concentrations in the seas of N.W Europe and hence no data with which to assess the impact of such marine impacts on the public health of marine stakeholders and coastal zone populations.
8: This Submission also contends that the demonstrated and repeated focus on limited parameters of potential dose exposure to LNA derived marine radioactivity (via sea foods and contact doses only) and the refusal to address any other form of exposure to marine radioactivity via other observed pathways (various forms of sea to land transfer: see Appendix 1) has similarly meant that there is insufficient data about the potential doses received by coastal zone populations in affected sea areas such as the Baltic and the Irish
seas.
9: This Submission contends that the extent facts now known about the near, intermediate and far field radiological impacts of LNAs on marine environments is poorly reflected in the ICRP Draft Document, which contains little of benefit or advantage to marine stakeholders and Coastal Zone populations in effected sea area.
10: This Submission contends that, in the context of the very public debate about the management and/or disposal of stored and radiologically contaminated Fukushima groundwater, the failure of the ICRP Draft document to address such issues is hard to justify./
11: This Submission calls on the ICRP to explain why their 90+ page draft document has had so little to say about marine specific issues despite its declared intention of seeking the Radiological Protection of People and the Environment in the Event of a Large Nuclear Accident.
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Three examples of LNAs with a marine impact.
1957 Windscale fire:
Despite the poor recording of actual event detail during the 1957 Windscale fire, it is clear that the marine environment was a major recipient of radioactive pollution via three pathways: fallout and washout directly onto marine surfaces, secondary inputs via runoff from contaminated terrestrial sources and deliberate disposal, to sea,via site and other drainage systems, of accrued radioactive wastes (contaminated milk and Emergency Cooling Water/ECW).
In the case of the Windscale fire, it is clear that there was very poor assessment and recording of the radiological nature of atmospheric discharges arising from the fire itself. There is no evidence that a full inventory of the atmospheric discharge was attempted.
It is equally clear that there was very little (if any) attempt to assess the amount of radioactivity in the liquid arisings following the application of the ECW which continued until the cessation of the fire. Accurate assessments of the volume of ECW (applied with up to a dozen fire hoses with their nozzles removed) have not been reported, and, it is assumed were not attempted.
It is equally clear that what analysis and monitoring of radioactive materials discharged to the environment was attempted, during and after the fire, was strictly limited to short (and relatively short) lived beta emitters and that no attempt was made to monitor the emissions and environmental behaviour and fate of longer lived and alpha emitting radio-nuclides.
I can find no evidence of an appropriate post event, marine environmental sampling and monitoring programme undertaken in order to gather and correlate relevant information about the distribution and behavior in marine environments and foodwebs of Windsdcale fire derived radio active, atmospheric and liquid releases.
This Submission therefore concludes that
A: NO data providing usefully detailed information on the marine environmental outcomes of the Windscale fire were collected,
B: the Windscale fire and it’s outcomes remain a data “black hole” in the context of non -existent data
C: the opportunity to learn what possible risk the event may have generated for marine stakeholders, workers and coastal zone populations of the Irish Sea was ignored and lost.
None of the issues discussed above have been referenced or addressed by the ICRP document
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1986 Chernobyl event In summary, the Chernobyl event, although it took place deep inland and hundreds of miles from the nearest marine environment, is shown to have had detectable and dramatic impacts on distant sea areas, depositing significant enhanced (relative to existing pre Chernobyl levels) of both short lived and medium lived beta emitters as well as long lived alpha emitters into both the Baltic and the Irish Seas. Rapid and very large increases in beta and alpha emitting radioactivity were recorded in marine environmental samples.
Official post event radiological investigation of Irish and Baltic Sea marine environments was characterised by a major focus on relatively short lived beta emitting nuclides and an almost complete avoidance of any investigation of the longer lived alpha emitters.
Commencement of Irish Sea radiological research was delayed for several days after the first contaminated rainfall was known to have occurred. In some marine environmental media, the commencement of research may well have not been timely enough to record peak concentrations of Chernobyl radioactivity.
Investigations of Chernobyl specific radiological impacts in Irish Sea coastal sediments were very limited (only 8 sites) and none of the samples from those sites were analysed for alpha emitters (Tables 8 & 9: UK Aquatic Environment Monitoring Report :AEMR 15).
UK monitoring of marine radioactivity was, by this time, more organised than it had been in the 1950s and the UK Aquatic Environment Monitoring Reports (AEMRs) were now into their 15th annual edition. The Chernobyl specific AEMR no 15: for 1986 (published in ’87), provided some useful data indicative of the impact of Chernobyl fallout on UK marine environments, although, as was the case with the Windscale fire reporting, the focus remained on the short, and medium lived beta emitting nuclides such as Iodine 131 and Caesium 137 and excluded any comprehensive review of long lived alpha emitter fallout and impact.
AEMR 15 reported that shoreline water concentrations of radioactivity increased after the first noted depositions of Chernobyl fallout on land and sea surfaces around the 28th & 29th April. Total concentrations of radio-nuclides in mussels (near high fallout areas) reached 10,000 BqKg around the Solway Firth, while other high fallout areas, areas such as the north coast of Wales, coasts of north west England (Cumbria and Lancashire) and northern Ireland also recorded major increases
While UK government agencies in their later AEMRs reported that these levels had declined in the post 1986 era, this did not mean that the radioactivity had “gone away”, because a study of later year AEMRs clearly shows that while concentrations did decline somewhat in the immediate vicinity of the most hard hit areas, concentrations at more distant marine sites within the Irish Sea rose over subsequent years, thus demonstrating that the Chernobyl inputs did not have a merely localised impact, but over time had a sea area wide impact.
Chernobyl marine environmental research focused almost exclusively on the behavior, fate and concentrations of short half beta emitters. Justification for this work appear to rest on the assumption that because such nuclides are present in the greater volume/quantity they represent a greater risk.
Some of AEMR 15s measurements provide useful quantification of the pre and post Chernobyl fallout impacts in waters receiving run off from highly contaminated areas. Thus Table 11 of AEMR 15 reports that winkles analysed for Cs137 at Southerness on the Solway prior to the Chernobyl event (Feb ’86) had Cs 137 concentrations of 15 Bqs/Kg, while Table 5 of AEMR 15 reports that by the 3rd of May (post fallout) winkles from the same site had concentrations of 805 Bqs/Kg (increase of x53).
Similarly Table 11 (AEMR 15) reports that Mussels from Conway, north Wales, had concentrations of 3 Bqs/Kg in March ’86, and Table 5 reports that mussels from the same site had concentrations of14.8 Bq/Kg on 13th of May (increase of x5).
Due to the small numbers of radio-nuclides investigated by the post Chernobyl monitoring programme instituted by UK government agencies it is not possible to be entirely clear about the results for other nuclides (almost no monitoring for alpha emitters was reported in AEMR 15). However some pre and post Chernobyl data can be extracted from other studies.
Such studies have demonstrated that long lived alpha emitters (Pu 238, Pu 239, Pu 240 and Pu 241) were discharged to atmosphere during the Chernobyl event, and that were aerially transported significant distances (100km + ) from the Chernobyl site Deposition and distribution of Chernobyl fallout fission products and actinides in a Russian soil profile.” Carbol.P. et al’. Journal of Environmental Radioactivity. 2003: 68 (1) : 27-46
A European Parliament summary of Chernobyl research contains Table 1 listing “Selected radioactive substances released by the Chernobyl Accident: EBq” (Iodine 131, Cs 137, Cs 134, Sr 90 and Pu 241). The text comments that “fuel particles and larger particles (containing mostly Sr and Pu) were deposited less than 100km away from the reactors” but offers no comment on the behaviour and end fate of smaller particles. Briefing April 2016 EPRS : European Parliamentary Research Service Author: Didier Bourguignon and Nicole Scholz Members' Research Service PE 581.972 EN C
Samples of coniferous forest litter collected in northern Poland( 400 miles + from the Chernobyl site) were analysed for α emitting plutonium isotopes. Specific as well as surface activities of the samples were determined. The observed maximum surface activity for Chernobyl fallout is above 25 Bq m−2, for all α-emitting Pu isotopes. The Chernobyl component was shown to be well correlated with the previously determined 144Ce activity, which supports the model of small fuel-like hot particles precipitation. Applied Radiation and Isotopes Volume 46, Issue 11, November 1995, Pages 1203-1211
Radioactive contamination of Baltic seawater after the Chernobyl event was dominated by Caesium 134 and 137. However, more than 20 different radionuclides were detected in the fallout soon after the accident. Many radionuclides, such as Sr-89, Zr-95/Nb-95, I-131, Te-132/I-132, Ba-140/La-140 were also detected in Baltic seawater but due to their short half-lives, decayed within several days or months. Small increases in Sr-90 and alpha-emitting plutonium isotope activity concentrations were observed within a year of the accident in those parts of the Baltic Sea where deposition was high. BALTIC SEA ENVIRONMENT PROCEEDINGS No. 61 RADIOACTIVITY IN THE BALTIC SEA 1984 - 1991 HELSINKI COMMISSION Baltic Marine Environment Protection Commission 1995
Measurements of Chernobyl derived radioactivity in Baltic sea water, 6 months after the Chernobyl event indicated that 50% of the regional Chernobyl related fallout had ended up in the Gulf of Bothnia (Finnish/Norwegian territorial waters are 700+ miles from Chernobyl), while, further south, the greater Baltic Sea was estimated to have received between 15 and 30%. The source for this is reported to have been both direct fallout to sea surfaces and subsequent inputs via run off from the terrestrial environment BALTIC SEA ENVIRONMENT PROCEEDINGS No. 61 RADIOACTIVITY IN THE BALTIC SEA 1984 - 1991 HELSINKI COMMISSION Baltic Marine Environment Protection Commission 1995
Given the demonstrated ability for Chernobyl derived alpha emitters to reach the Baltic environment, it is not impossible for such material to have reached have reached the Irish Sea and such an outcome may be supported by the available evidence from the AEMRs.
Thus AEMR 14 (pre Chernobyl 1985 data) reports in Table 10 that maximum Plutonium 239/240 concentrations in coastal silts at Kippford Merse on the Solway coast were 380 Bqs/Kg. AEMR 15 did not monitor for alpha emitters at comparable sites, but AEMR 18, reporting wider (not Chernobyl specific) marine monitoring for 1986, reported that Pu 239/2490 concentrations at Kippford Merse had risen to 420 Bq/Kg (Table 10): a 10.5% increase for a one year period
AEMR 14 (pre Chernobyl 1985 data) reports in Table 10 that maximum Americium 241concentrations in coastal silts at Kippford Merse on the Solway coast were 460 Bqs/Kg. While AEMR 18, reporting wider (non Chernobyl specific) marine monitoring for 1986, reported that Am 241concentrations at Kippford Merse had risen to550 Bq/Kg (Table 10): a 19.5% increase over a 1 year period.
No explanation is offered for this relatively large annual percentage increase in the presence of the Pu 239/240 and Am 241 in Solway sediments, however, in the absence of evidence to the contrary, it may be postulated that this is a demonstration of the presence of Chernobyl derived alpha emitters entering the Irish Sea and giving rise to elevating concentrations of alpha emitters.
Secondary (post incident) re-distribution of Chernobyl radioactivity: In the aftermath of (post event) forest fires in the Chernobyl exclusion zone, a 2006 study of controlled grassland and forest fires was carried out at experimental plots within the zone in order to determine the parameters of the radioactive aerosols resuspension, transportation and deposition under well-described conditions. Radionuclide airborne concentrations, resuspension factors, deposition intensity and velocities and dispersal composition of the radioactive aerosols were measured and doses to firemen from inhalation of radio-nuclides were modelled. The study noted that an increase of several orders of magnitude of airborne radioactivity concentrations (Cs 137, Sr 90 and Pu nuclides) was observed in the vicinity of the fires. It was also noted that the Pu nuclides constituted the dominant dose to firemen, by inhalation. “Resuspension and redistribution of radionuclides during grassland and forest fires in the Chernobyl exclusion zone: part 1. Fire experiments”. Yoschenko,V.I. et al’. Journal of Environmental Radioactivity. 2006 Journal of Environmental Radioactivity. 2006. 86(2). pps 143-163.
It was also calculated that “up to 4% of the Cs 137 and Sr 90 and up to 1% of the Pu nuclides” were released to the atmosphere during the fires. “Resuspension and redistribution of radionuclides during grassland and forest fires in the Chernobyl exclusion zone: part 22. Yoschenko. V.I. et al’. Journal of Environmental Radioactivity. 2006. 86(3). pps 260-278.
These studies demonstrate the very real possibility of secondary contamination of distant terrestrial and marine environments, by radioactivity deposited around a nuclear accident site, decades after the accident had occurred.
A 2014 study noted that “During the last 28 years dead wood and litter have dramatically accumulated in these areas, whereas climate change has increased temperature and favored drought. The present situation in these forests suggests an increased risk of wildfires, especially after the pronounced forest fires of 2010, which remobilized Chernobyl-deposited radioactive materials transporting them thousand kilometers far”.
The study modelled the potential redistribution of Cs 137 under different fire conditions and concluded that the resulting releases of (137)Cs after hypothetical wildfires in Chernobyl's forests are classified as high in the International Nuclear Events Scale (INES) and likely to lead to an increase in human health impacts. “Wildfires in Chernobyl-contaminated forests and risks to the population and the environment: a new nuclear disaster about to happen?” Evangeliou.N. et al’. Environ Int. 2014. Dec:73:346-58
It is clear from such studies that there is a real potential for secondary, delayed, tranches of radio-nuclide deposition on to distant terrestrial and marine surfaces in the short, medium and probably the long term, following the Chernobyl event.
None of the issues discussed above have been referenced or addressed by the ICRP document
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3: The Fukushima event is notable for the greater media coverage given to marine impacts arising from both the initial disaster and the subsequent events. However, research, by Japanese Government agencies and the nuclear industry (Tepco and IAEA), on marine environment radiological issues remained littler better than that conducted on the Chernobyl marine impacts, despite the much more direct and immediate impacts on coastal waters.
It has been widely reported by Japanese Agencies, TEPCO and the IAEA that during the initial phase of the event 3 of the Daiichi reactors suffered both reactor and Spent Fuel Cooling Pond (SFCPs) LOCAs, loosing at least the majority (and probably the entirety) of their coolant to the environment. Millions of tonnes of Emergency Cooling Water (ECW) were subsequently applied to both reactors and SFCPs. The vast majority of both coolant and ECW is agreed to have entered the marine environment.
Subsequently, ground water flooding into the site has been found to be heavily radiologically contaminated with material from the reactor core. Some of this water also escaped into the marine environment, far more of it has been impounded and collected in storage vessels, where some (but not all) of the radioactivity has been extracted leaving a heavy burden of tritiated water as yet untreated/un-extracted. It is now clear that the available storage potential for this liquid is in danger of being overwhelmed and there are strong calls from TEPCO and Japanese government agencies for permission to discharge at least 250 million gallons of this water to the sea.
Post event response investigation has been characterised by flaws and weaknesses similar to those seen during the Windscale fire and the Chernobyl event.
In the context of the ongoing contamination of the marine environment following the multiple meltdowns and loss of coolant from the Fukushima site I note the ongoing near-site monitoring of the marine environment (sea water) and of some marine environmental media (principally fish, with some marine algae). However I am deeply concerned to note that a number of highly relevant issues and phenomena relating to the behaviour and fate of the Fukushima sea discharged radioactivity and its potential for delivering doses to human populations remain un-recorded, under researched and/or completely ignored.
Various marine environmental sampling programmes have been undertaken by TEPCO, Japanese government agencies and the IAEA but these have all been characterised by
a: a very narrow range of nuclides/isotopes analysed for
b: an evidently 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
As with the Windscale and the Chernobyl scenarios reviewed above it is clear that the TEPCO and Japanese Agency monitoring programme , presumably based on IAEA protocols, was based on the intensive measurement of short lived beta emitters such as Iodine 131 and Caesium 134/137, while the most long lived and radio-toxic nuclides such as the Plutoniums and Americium were not investigated by the above bodies. Justification for this course of action focuses on the proposition that beta emitters (by virtue of the volume discharged) represent the greater radiological risk to human health.
However the empirical facts of the marine cases under consideration are dependent on the nature of the differing dose delivery pathways of beta and alpha emitters in marine environments. Studies of sea to land transfer (see Appendix 1) inadequate and incomplete though they are, have clearly demonstrated that the behaviour of alpha emitters in marine environments differs markedly from that of beta emitters.
Concentration factors of Pu 329/240 ADsorbed to sedimentary (clay/mineral) particles and to marine micro-algae were reported to be as high as 26,000 in sea surface microlayers. The presence of micro algae and sedimentary particles in sea spray was linked to the high enrichment factors of Pu 238, 239, 240 and Am 241 (EFs of several hundred) compared to ambient seawater, recorded during the investigation of marine aerosols transferring from the sea to the land across the Sellafield coast of the UK.
By contrast there is a consensus that the beta emitting Cs has only a slight association with organic and mineral particles in the marine environments and that it’s enrichment factors during sea to land transfer (sea spray and aerosol) processes rarely exceed EFs of around 2, relative to ambient sea water.
By contrast, alpha Pu and Am nuclides are widely shown to have high enrichment factors (relative to ambient seawater) in marine sediments. Consequently, episodes of coastal inundation where large volumes of radiologically contaminated sediment are carried ashore (super tides, storm surges, tsunami etc) have been shown (when investigated) to generate exceedance of GDLs for Am and Pu and positive risk to clean up workers from inhalation doses.
Empirical (not modelled) studies of sea to land transfer have clearly demonstrated that marine Caesium, blown ashore in sea spray and marine aerosols during onshore winds, is responsible for delivering dietary doses from contaminated terrestrial foodstuffs grown in the coastal zone. It has been shown that coastal zone dwellers may receive higher doses of Cs 137 from their consumption of coastal zone foodstuffs than from sea foods and that such sea to land transferred, airborne radioactivity may penetrate at least 10 miles inland. The inevitability of the delivery of airborne radioactivity doses, to those breathing coastal zone air, is clear.
However, despite the empirical evidence gathered from UK studies (see Appendix 1) there has been no evidence that TEPCO, Japanese Government Agencies or the IAEA have engaged in any attempt to investigate the doses to coastal zone populations either in the vicinity of, or downstream of, the Fukushima site
Additionally, despite the fact that alpha emitters such as Pu and Am have clearly been shown to transfer from the sea to the land, via sea-spray and aerosol mechanisms, just as frequently as Caesium (but with much greater EFs), there is no evidence that any Japaanese Nuclear Industry or Government Agency body has attempted empirical assessment of either alpha emitter dietary doses from the consumption of contaminated terrestrial produce, or of any alpha emitter inhalation doses from breathing coastal zone air during periods of onshore wind, across the Pacific coast of Honshu.
This Submission contends that, since the available evidence demonstrates that short lived beta emitting nuclides such as Caesium and Iodine do not undergo the high degree of re-concentration (in either marine sediments or marine sea spray/aerosols) as is observed for long lived alpha emitters, the widespread and historical refusal to address the issue of alpha emitter impact on marine and coastal environments following LNAs is deeply flawed.
This Submission concludes that the sea to land transfer of long lived alpha emitters via the sea spray and aerosol transport pathway exposes coastal zone populations to a set of specific dose pathways via the consumption of coastal zone foodstuffs and the inhalation of coastal zone air. In that context, this submission concludes that it is evident that the true impacts of the radioactive contamination of the Japanese east coast are not being documented or acted upon.
Review of “official” marine analytical monitoring programmes initiated in the wake of the Fukushima event confirm that the marine geographical extent of those programmes has been strictly limited and therefore incapable of providing a true picture of the behaviour and fate of Fukushima derived contamination and its potential impact on Japanese coastal zone populations in the downstream zone. It is clear that Nuclear Industry and Japanese government agency investigations have been restricted to sea areas in the relatively immediate near field of the Fukushima site, over 100 kms offshore, to coastal areas largely to the north of the Fukushima site and to Tokyo Bay. Adoption of such a monitoring policy is deeply flawed as it ignores some of the basic facts about the coastal marine dynamics of the Honshu coast.
UK research shows that sea to land transfer mechanisms can occur at least 200kms (by sea) distant from the point source of radioactivity, and that populations living in such areas are exposed to terrestrial food stuffs which deliver a higher marine radioactivity (dietary) dose than regionally harvested sea foods. UK resea
populations “distant” from a discharge point of “liquid” radioactive wastes, may receive higher doses of marine radioactivity through their local terrestrial diet, than populations living closer to the point source receive through their local sea foods.(See Appendix).
This is shown to be the case at distant sites “downstream” or “down current” from the point source, and is particularly associated with inshore waters with elevated burdens of suspended particulate matter.
(post) FUKUSHIMA) marine radioactivity monitoring: marine and coastal parameters requiring assessment. There is a strong consensus among oceanographers that the major water body movements, and hence the major drivers of marine pollutant transport off the Pacific coast of Honshu Island, are the Oyashio, and the Kuroshio currents.
In the Fukushima coastal region the Oyashio is the dominant of current. It is a strong flowing current carrying cold, nutrient rich polar water close to the entire length of the east coast of Honshu from its northernmost extreme, southward to the region around the mouth of the Tone River in Chiba Prefecture, where it meets the Kuroshio current.
The Kuroshio current originates in the Phillipine Sea, transits past the south coast of Honshu and collides with the Oyashio in the region of southern Chiba Prefecture. The combined current streams then trend east and north-eastward away from the Japanese coast and out into the ocean as the North Pacific Drift Current. The water in this current, at offshore locations has received some investigative attention (mainly from non-nuclear and non-Japanese academics) due to its potential to carry radioactive material from Japan towards North America.
Interactions between the Oyashio and the Kuroshio are variable on seasonal, annual and longer term time scales. Thus, southerly or northerly penetration of either current is not fixed and eddy formation varies from year to year. There is a consensus that climate change parameters are having an influence on both currents and their interactions, but long term trends remain very uncertain. Although the southward trend of Oyashio surface water along the east coast of Japan is not in doubt, the understanding of possible seabed/bottom currents in the region is less certain.
It is clear that the action of the Oyashio current in the region of Fukushima will have carried much of the Fukushima radioactive marine plume southwards along the Honshu coast until it’s meeting with the Kuroshio, approximately 200 kms to the south. Despite this fact there has, as indicated above, been very little investigation of the radiological consequences of the Fukushima event on the coastal zone, intertidal, estuarine and inshore marine environments of this 200 km stretch of downstream coastline. Subsequently, there is no data on fisheries impacts, dietary doses or sea to land transfer dietary/inhalation doses to the population of the extensive “downstream” Coastal Zone.
Tritiated water issues have been widely commented on over the last few years, as storage of radioactively contaminated ground water etc flowing into and through the Fukushima site in the post event phase has been necessary to prevent it’s escape into the marine environment.
Japanese Government Nuclear Regulators, TEPCO and the IAEA have all vigorously promulgated the myth that after that water has been “stripped” of the majority (by volume) of other nuclides, the stored water containing now much lower concentrations of other nuclides and the full complement of Tritium, is safe for discharge to the marine environment. However this is a deeply flawed proposition based on a now wildly outdated historical (nuclear industry) assumption that Tritium, with a half life of 12.3 years, is a beta emitter which dissolves and dilutes to infinity in aquatic environments and is therefore harmless to the environment and the public.
However, independent academic research outcomes published since the late 1990s have clearly demonstrated that these assumptions were false and no longer have any scientific support. Now it is clearly understood that Tritium can enter marine food webs by becoming bound/incorporated to organic material in the marine environment and that this leads to major bio-concentration factors of Organically Bound Tritium (OBT) in marine and coastal zone foodwebs.
A 1999 study in the Bristol Channel, (a high tritiated water discharge region) observed that ambient sea water concentrations of Tritium were around 10 Bq/Kg. However, following organic bonding it was observed that intertidal sediment concentrations (now largely consisting of OBT) were as high as 2,500 Bq/Kg. Mussel flesh held concentrations up to 26,000 Bq/K, Cod flesh had concentrations up to 33,000 Bq/Kg and wildfowl had concentrations up to 61,000 Bq/Kg
A subsequent 2001 study reported that tritium became incorporated into organic material at the cellular and micro particle level in marine environmental biota, and that the process involved absorbtion of tritium into proteinaceous and lipid material. A further, 2009, study recorded concentration factors in “excess of 100,000” in some demersal fish and shellfish species. Clearly the potential for very significant dietary doses to human consumers is very high from seafoods.
Given the observed ability of Tritium to become absorbed into organic cellular and particulate matter in marine environments, there is clearly a possibility for such material to be transferred from the sea to the land via sea-spray and aerosols or during coastal inundation episodes. No studies of this mechanism have been identified, thus there is no understanding of the behaviour and fate of Tritium and OBT during such processes. However, in the context of the study of other nuclides transferring from the
sea to the land, the probability of dietary and inhalation doses of OBT being delivered to Coastal Zone Critical Groups is relatively high. In the context of both the recently emerged evidence of the behaviour of Tritium and OBT, and the ongoing ignorance of some of the potentially significant parameters, the comments of Japanese Agencies, TEPCO and the IAEA are deeply irresponsible.
In the context of considerations about how to respond to LNAs, the failure of the ICRP Draft Document to address the issue of the tritiated water at Fukushima is a significant weakness in the ICRP proposals.
APPENDIX 1
Originally presented as
Sea to Land Transfer Briefing:
To Welsh Assembly
Senedd Petitions Committee 2nd Meeting:
5th December 2017
Tim Deere-Jones
(Marine Radioactivity Research & Consultancy)
INDEX
Re-concentration of radioactivity in marine environments………………………………..page 3
Studies of Sea to Land Transfer by AERE ………………………………………………………….page 4
Flawed measuring technologies ……………………………………………………………………….page 4
Further studies on the Cumbrian coast …………………………………………………………….page 5
The RADMID REPORT: Dyfed County Council ……………………………………page5
North Wales coastal zone : sea to land transfer………………………………… page 6
Hebridean case study…………………………………………………………………………………………page 6
North Wales case study: sea to land transfer by storm surge………………page 7
Flawed reporting of sea to land transfer…………………………………………………………….page 8
Flawed dose estimation……………………………………………………………………………………..page 8
Incomplete information on Sea to Land Transfer………………………………………………page 10
Poor access to official research/review…………………………………………………………….page 11
References ………………………………………………………………………………………………………page 12
Studies of Sea to land transfer of marine radioactivity: sea spray and marine aerosol pathway
1: Reconcentration of radioactivity in the marine environments of the Irish Sea
1:1 For generalized marine science purposes the designation “Irish Sea” =
a: the northern basin (between N. Ireland and the north west of England)
b: the southern basin (Between the Irish Republic and Wales)
c: the Bristol Channel
although each of these sea areas are dis-similar in some environmental respects
1:2 UK Government and Nuclear Industry 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)
1:3 The above referenced study also reported on investigations of the enrichment of marine aerosols and 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.
1:4 Other studies by the UK Nuclear Industry and Government Agencies report EFs (relative to ambient seawater) of 812 for Am 241 in sea spray and 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.
1:5 Studies such as these have conclusively demonstrated that marine radioactivity transfers (in aerosol and sea spray) from the sea to the land during periods of onshore wind accompanied by breaking waves and the generation of bursting bubbles and foam in both offshore and inshore environments. (Ref 8)
1:6 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.
1:7 Additionally 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)
Studies elsewhere have clearly shown that marine micro-organisms may be blown ashore and penetrate at least 50 miles inland. Thus there are good grounds for stating that radioactively contaminated marine organisms may be blown ashore from Irish Sea/Bristol Channel environments believe that
1:8 It has also been demonstrated that soluble nuclides such as Caesium 137 become enriched in wet marine sediment deposits in UK coastal and inshore waters (relative to concentrations in ambient marine water).
Thus, recent monitoring carried out in the marine environment adjacent to the Hinkley Point discharge pipeline reports:
a: seawater concentrations of Cs 137 (taken at the pipeline) of less than 0.33 Bq per kg
b: sediment concentrations of Cs 137 (at four intertidal sediment Bridgewater Bay sites) ranging from 7.7 to 28 Bq per Kg. (max enrichment factor of 84)
(Ref 12)
1:9 It is thus a well reported and well understood fact that there are multiple 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/re-concentrate to levels many times higher than the ambient sea water at the point source of input/discharge
1:10 In this context, the original simple hypothesis, adopted by Government and Government regulatory agencies, that discharged liquid radioactivity will dilute and disperse until it reaches “background” concentration is now shown to be both simplistic and deeply flawed.
It is plain that the bbehavior 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, sea spray and aerosols)
2: Sea to Land Transfer Studies by the UK AERE (UK Atomic Energy Research Establishment),
2:1 Studies through the late 1970s & early 80’s, found that:
a: several nuclides of Pu (Plutonium) and one of Am (Americium 241) were found to be airborne during onshore wind conditions, in any coastal area where the field work was carried out, 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: warned 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 any appropriate equipment.
(Refs 20, 21 & 22)
2:2 The Flawed Technology
AERE used muslin screens 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.
2:3 Muslin screens were originally deployed as a back up to the use of the 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 )
2:3 However it was reported that muslin screens also provided inherently inaccurate data because as wind speeds increased (especially beyond Force 5) the muslin stretched and its porosity increased, allowing more and more (and larger and larger) particles to pass through the material.
2:4 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 as high as 50% (efficiency had decreased by 50% of whatever it would be at minimum wind speeds).
Accordingly, the authors warned that muslin screens should be used “only as a qualitative tool to compare relative concentrations of actinides in sea spray” (Ref 21)
2:5 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
2:6 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.
3: Further studies on the Cumbrian Coast
3:1 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 20km inland were analysed for the insoluble nuclides Plutonium and Americium in 1982
3:2 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)
3:3 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 almost entirely:
a: on the coastal areas of the northern basin of the Irish Sea in the vicinity of the Sellafield sea discharge point sources
b: and entirely on Plutonium, Americium and Caesium, (to the exclusion of the other 50+ radio- nuclides listed as constituents of liquid radioactive discharges from Nuclear Power Stations)
c: thus it can be stated that the vast majority of radio nuclides discharged to sea from NPS have not been investigated in respect of their ability to transfer from the sea to the land
4: The RADMID Report (Radiation Monitoring in Dyfed)
4:1 Through the mid 1980’s research was carried out by the citizens group “The Irish Sea Project”, of which I was the research director, on aspects of the behaviour and fate of man-made radioactivity along the Welsh coast., following the revalation that there was no available data for the Cardigan Bay coastline
4:2 The 1986 “Teifi Estuary Study” in south west Wales sampled the estuarine sediments of the R.Teifi (Ceredigion) and discovered that they held concentrations of Sellafield (sea discharged) Caesium 137 and Americium 241. The ISP study also found that the finer, inter-tidal estuarine sediments, located in the more inland sectors of the estuary held up to 10X higher concentrations of both Cs137 and Am 241 than the coarser sediments located at the seaward end of the estuary. REF “Survey of Radioactivity in the Teifi Estuary: 1986” IRISH SEA PROJECT (copy available from the author: TD-J)
Representatives of BNFL and the UKAEA later confirmed that the radioactivity observed in the Teifi Estuary had indeed originated from the Sellafield sea discharges
4:3 In 1987-88 Dyfed County Council commissioned a follow-on study of radioactivity (RADMID) in the county, 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.
4:4 This study confirmed the presence of “low levels of Caesium 137” (proved to have been derived from
Sellafield sea discharges) in pasture grass and hay, “in excess of 10 miles inland of the Cardigan Bay coast
of south west Wales” (Ceredigion), and of Uranium decay products assigned to the Springfields
nuclear fuel factory on the Lancashire coast. (Ref 23)
The RADMID data confirmed
a: an unexpectedly deep inland penetration of these isotopes
b: that radioactive waste, discharged to sea from multiple distant sources was available for entry into the regional terrestrial dairy and meat food chain
c: and strongly indicated its likely entry into other local arable and horticultural produce chains
d: and raised the probability of inhalation doses (Ref 23)
5: North Wales coastal zone case study: Sea to land transfer via sea spray/aerosol
5:1 A 1987 UKAEA (UK Atomic Energy Authority) study of sea to land transfer, used air and
rain sampling stations at 5 sites in north Wales. Air sampling was carried out using both
the muslin screens and the air samplers, previously recognised as inefficient and NOT
to be used for quantitative purposes.
5:2 The study demonstrated that “low levels” of Caesium, Plutonium and Americium were
transferring from the sea to the land, across the north Wales coast and that Sellafield
was the likely source. The study included one inland site, at Dyserth, where positive
results for Am 241, Pu 238, Pu 239, and Pu 240 where observed. Enrichment factors
were not investigated.
REF:
JA Garland et Al’ . “Artificial Radioactivity on the Coasts of Wales:” UKAEA:
Environmental Radioactivity in Wales.(DoE Ref PECD 7/9/368)., July 1989
6: Hebridean case study
6:1 In a pre-Chernobyl study of patients from North Uist (Western Isles of Scotland), an independent medical team found excess Caesium 137 body burdens compared to those in patients from the Scottish mainland and investigated the source of Cs in the N.Uist patients.
6:2 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.
6:3 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)
6:4 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 islander’s diet. Islander doses for total nuclides will plainly be greater than the calculated dose for CS only.
7: North Wales: Sea to Land Transfer by Coastal flooding
7:1 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.
In 1990, at Towyn, on the North Wales coast, a storm surge caused extensive flooding of the coastal zone, damaging caravan/holiday parks, shops and houses.
Many tonnes of near-shore, previously sub tidal, marine sediment were deposited as a result of the storm surge. 14 samples of this sediment were taken and subjected to laboratory analysis for Am 241 and Cs 137.
7:2 The analysis showed that both Americium 241 and Caesium 137 were present in the marine sediment and that Americium levels in most samples exceeded 20 Bq/Sq metre, the “Contamination GDL” for Am. 8 of the 14 samples exceeded the GDL level by “more than ten times) (i.e. above 200Bqs/Sq metre)
NB: GDLs (Generalised Derived Limits) were the concentrations in environmental media estimated to result in an annual dose, to members of the public, of 1mSv, the dose limit recommended by the International Radiological Protection Committee and endorsed by the then UK National Radiological Protection Board. It is recommended that where GDLs are exceeded by 25%, further investigations into the public implications are undertaken. There is no evidence that such further action was taken at Towyn.
7:3 The Consultant’s report also stated that
a: the presence of Am 241 “also implies the presence of the plutonium isotopes Pu238, Pu 239, Pu 240 and Pu 241 and quite probably the GDLs for these will also be exceeded”
b: “contamination due to americium, and probably also of plutonium isotopes….. is generally greater than limit set….for further investigations”. (i.e. the GDL)
c: “the values suggest that, when the sediment dries out, there is a possible radiation hazard due to the inhalation of radioactive dust containing the isotopes of americium and plutonium”
REF: Edinburgh Radiation Consultants: “Radiation Survey of Towyn “: March 1990. (Consultant retired) (copy of report available from Tim Deere-Jones)
8: Flaws and failures of Sea to Land transfer reporting
8:1 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.
8:2 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.
8:3 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.
8:4 Reports for most existing and proposed new build reactors list over 50 constituent radio nuclides in liquid discharges to sea. One table issued by Westinghouse, the manufacturers of the proposed 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 radio nuclides.
The list of expected constituents in the proposed Hinkley C liquid discharges contains 79 named radio nuclides
8:5 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 re-suspended particulates including those from the surf line”.
In support 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.
NB: It is 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.
9: Flawed Dose estimates
9:1 It the context of the above, it of the utmost relevance to note that
a: the dose calculations undertaken for the above mentioned 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
9:2 Thus it can be seen that the MAFF AEMR No 23 had uncritically and mistakenly carried forward a series of errors and lapses in information to the public and that the calculated doses were deeply flawed because
a: based on the effect of only 2-5 (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
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 5 times higher than the eventual agreed level of 1mSv.
9:3 This catalogue of specific inaccuracies about dose rates by inhalation via the marine sea spray/aerosol pathway were repeated in subsequent MAFF AEMR and the later RIFE reports 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.
9:4 By 2000, the issue of re-suspended particulates in sea spray from the surf zone had been dropped from Reports and replaced by a discussion of “re-suspended beach sediments”.
NB: From a Marine Science perspective, re-suspended 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 is true of “beach sediments” because
`a: “beach” is not equivalent to those mud flat or salt marsh environments where fine sediments deposit out
b: “beach sediments” are those found deposited out on beaches and are generally of larger particle size (sand - cobbles) 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 due to the size of beach particles (sand or larger)
d: re-suspended (sand) 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 or distance inland))
9:5 Radioactivity in Food and the Environment (RIFE-5: pub’ 2000) page 40, under the heading “External exposure”, makes no mention of inhalation of re-suspended particulates including those from the surf line but does report that
“inhalation of re-suspended 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)
9:6 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/sea spray 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 above with regard to investigating a very limited group of nuclides and making use of outmoded and redundant ICRP dosimetry.
9:9 Thus the annual RIFE reports regularly report the detection of Technetium 99 and other artificial nuclides, at Ravenglas, and also identification of (“probably Sellafield derived”) transuranic nuclides such as Pu 238, Pu 239 and Pu 240 in samples: thus further 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)
9:10 In the context of the above analysis, it is concluded 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 PRECISE QUANTIFICATION of sea to land transfer of radionuclides in marine aerosols and sea spray are available or have been deployed.
9:11 It may be concluded that industry and government attempts to calculate potential doses to the public arising from sea to land transfer mechanisms remain both inaccurate and incomplete and do not provide sufficient precision data for the modeling of human doses.
10: Incomplete “official” information on the issue of Sea to Land Transfer of radioactive wastes
10:1 There has been, and continues to be, a major problem due to the lack of appropriate research. One of the major problems has been
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 (i.e. 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).
10:2 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.
However the N.East basin of the Irish Sea is NOT an exact replica of other sea areas within the Irish Sea, where conditions differ and the fate and behaviour of radioactivity may reflect those conditions.
10:3 Bristol Channel environmental parameters differ widely from those found in the NE Basin of the Irish Sea (e.g.: generally far higher loadings of mobile sediment than those found off the Cumbrian coast) plainly this will have an influence on issues associated with the fate and behaviour of sediment associated radio nuclides in the Bristol Channel.
10:3 It is disappointing to note that despite the available evidence that sea to land transfer is occurring (wherever researched) along Irish Sea and Welsh coasts, there has been a notable failure to engage in appropriate “follow up” research in order to confirm
a: the true extent of the inland penetration of beta radioactivity (Caesium 137 etc) and alpha radioactivity (Plutonium and Americium etc)
b: the sea to land transfer potential of the totality (50+ man-made radioactive substances) of sea discharged radioactive wastes
c: pathways of radioactive dose delivery to coastal populations as a result of sea to land transfer
10:4 In the context of the previous/above paragraphs I conclude that the available information demonstrates a lamentable disregard of the extent empirical data on the facts and implications of sea to land transfer of marine radio activity.
10:5 I further conclude that the research effort to date, has been timid, incomplete, fudged and mis-handled and shows a lack of interest in following through on the data gathered by what most sensible observers would call “preliminary studies”, the outcomes of which have strongly indicated a major potential issue regarding the human health effects of the sea to land transfer of man made, sea discharged radio activity and the subsequent urgent need for further investigation!.
10:6 While it not surprising that the Nuclear Industry has no interest in further in-depth follow through studies, the fact that such follow on work has NOT been undertaken by the UK Government Regulatory Agencies is a major dereliction of the duty entrusted to them
11: Issues over access to Official research and review data
11;1 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.
11:2 One notable example has been the attempt by myself, and some campaign and citizen’s groups, to access a copy of a UK Government/Regulating Agency review of Sea to Land Transfer issues entitled
“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 was much referenced in early 2000’s annual RIFE reports and other documents, in support of the arguement that sea to land transfer is of low radiological and public health significance.
11:3 However, applications for a copy of this paper, made to the successively to the libraries of DETR, CEFAS, DEFRA, DECC, the Environment Agency and even to the author himself (now working for the DECC) were met with the reply that it is no longer available. Unfortunately it has not been 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. However attempts through the early 2000’s and from this year, have failed to elicit any disclosure.
11:4 11:3 Plainly access to such a document for information and review purposes would be of major importance for researchers and campaigners alike. The inability or un-willingness of Government Departments and Agencies to produce this document speaks volumes.
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40: Environment Agency. GDA ASSESSMENT Report AP1000 Assessment report: Aqueous Radioactive Waste Disposal and Limits.