Transporting nuclear waste from Scrabster to Barrow >>>>>><<<<<< Risks to Public H

1. Transporting nuclear waste from Scrabster to Barrow >>>>>><<<<<< Risks to Public Health, the Environment and Economy of regional coastal communities. >>>>>>><<<<<<< Tim Deere-Jones : Marine Radioactivity Research & Consultancy

2. Govt Policy statements on transports of rad’ waste admit that “any transport (of radioactive materials) will, of necessity, increase conventional transport risks” [semantics] (Policy for long term management of solid LLRW in the UK: March 2007/ Welsh Assembly/Scottish Assembly DoE/DTI/DEFRA) • Government Statements on rad’ waste management repeatedly refer to the PROXIMITY PRINCIPLE: which states that Nuclear operators should “treat and/or dispose of wastes in reasonable proximity to their point of generation.” & “The principle seeks to minimise the environmental, public health impacts and the costs of waste transports” (UK Management of Radioactive Waste: NWP-REP-077 May 2015)

3. Cargo grades • Definition of IMDG 7 • rad’ mats in instruments/articles • Articles manufactured from natural U, depleted U or natural Thorium • Ores containing U or Thorium or concentrates thereof • Tritiated water, uranium hex • Surface contaminated objects (alpha, beta, gamma) • U and Thorium metals liable to spontaneous ignition • FISSILE materials: including enriched U hex with more than 1% U235, and U233, U235, Pu 238, Pu 239, Pu 241 or any combination likely to undergo criticality

4. Definition of INF 1, 2 & 3 • INF1: • Cargo with aggregated radioactivity less than 4,000 TBq (since 1 TBq = 1,000,000,000,000 Bqs) =4,000, 000,000,000,000 Bqs • INF 1 is permitted for carriage on normal merchant vessels (ferries, freighters, container ships etc) • INF 2 : • Cargo of irradiated nuclear fuel or HLRW less than 2X 10 (power 6) TBq or Plutonium with aggregated radioactivity less than 2X 10 (power 5) TBq • Usually carried on dedicated vessels (Atlantic Osprey,Oceanic Pintail) • INF 3 carry irradiated nuclear fuel, HLRW or Plutonium withUNLIMITED maximum aggregated radioactivity (must be carried aboard dedicated vessels and not on passenger vessels) • Could be equal to Chernobyl/Fukushima aggregated rad’

5. Sellafield annual total aggregated liquid discharges (radioactivity yield) relative to INF 2 & 3 cargo • Sellafield annual liquid total discharges 2014 = 200,413 TBq (aggregated radioactivity yield) • INF 2 permitted aggregated rad’ yield 10,000,000 (10 million) TBq • INF 3 unlimited aggregated rad’ yield

6. Dounreay Exotics Group 1 material • 13 tonnes: Un-irradiated Pu bearing fuels, containing “around 2 tonnes of Pu” (powders, pellets, pins and metal coupons) Group 2 material • 1 tonne highly enriched uranium fuels consisting of U Oxide (powders, pellets and uranium metals & alloys) Group 3 material • 12 tonnes irradiated fuels: “vast majority” is Prototype Fast Reactor (PFR) Fuel (nature/form not given) • PFR fuel achieves “very high burn up” and thus “requires special handling and transportation arrangements” • No details of aggregated radioactivity yield made public: but description appears to fulfil definitions of INF3 cargo

7. Non Transparency of shipment info Will the public be informed? • “The only information we cannot disclose is detail which might compromise the safety and security of any particular movement, such as precise routes, timings, quantities and security arrangements.”: (PNTL/INS/NDA PR material)

8. IAEA flask/package test requirements:“flasks are designed to remain safe in ALL credible accident scenarios” • a 9 metre drop test onto an unyielding surface • a 1 metre drop onto a steel punch bar • a fire test in which the package is subjected to a fully engulfing fire of 800°C for 30 minutes; ….not credible scenario • (Because ship fires frequently achieve + 1000 degrees & burn for many hours: can be days) • an immersion test where the cask is subjected to conditions equivalent to 15 metre submersion for 8 hours. even in best case salvage most unlikley in 8 hours • For casks designed for most highly radioactive materials, there is an enhanced immersion test of 200 metres for 1 hour….not credible scenario Even in best case: Salvage impossible in 1 hour

9. Pink 50/100 metres, pale blue 100/200, mid blue, 200/1000, dark blue 1000 metres+: NB: individual features like Beaufort Dyke exceed 200 metres

10. PNTL design flaws & safety claims Design collision vessel: • PNTL design (1970s) built to survive impact from 24,000 tonne vessel at 15 knots • BUT contemporary super tankers: 300,000 tonnes +, 16 knots Container ships: 150,000 tonnes+, 20 knots, Gas Tankers:164,000 tonnes +, 19 knots • All above vessel types regular users of sectors of the Scrabster/Barrow route • All above vessels regular users of route relevant choke points (Clyde approaches, Minches/Inner Sea, Outer route, North Channel, and “Port Approaches”)

11. PNTL design flaws and safety claims The “safety features” of PNTLs ships include: double hull construction around the cargo areas with impact resistant structures between hulls (but note design collision vessel discussion) duplicate safety-related equipment (navigation, communication, cargo monitoring, electrical and cooling systems, satellite navigation) BUT: these features all situated in single hull sections AIS :ship automatically transmits its position back to a manned control centre in the UK; ( re salvage & rescue etc) …..Commonly switched off by PNTL’s when vessels at sea • extra fire detection and fire fighting equipment located in single hull sections • twin propellers and engines which operate entirely independently twin engines in single hull section • powerful bow thrusters to provide greater manoeuvrability at slow speeds Controls etc located in single hull sections Above material direct from PNTL/INS/NDA PR material (except italics!!!)

12. PNTL design claims: “unsinkable”, “ship within a ship”, “collision resistant”NB: IEVOLI SUN!!!!

13. Ievoli Sun • Ievoli Sun : Class 2 Chemical Tanker • Purpose built (1989) to the IMO’s INC Code standards (later design than PNTLs) • 95% double hulled ( 35% greater than PNTLs) (only a small sector of the bow was single hull) • Similar size to PNTLs and supplied with similar or more advanced safety features • Vessel took on water during a heavy storm, the forward compartments flooded, vessel became “bow heavy” and lost manoeuvrability, was taken under tow by a rescue tug but eventually sank may miles offshore with a full cargo aboard.

14. Oceanic Pintail (INF 3) • OCEANIC PINTAIL named as vessel for Scrabster/Barrow transports • Oceanic Pintail = “upgraded” ex Pacific Pintail ( upgrade details not available) • Pacific Pintail the youngest/last of the first design PNTL ships: built in 1987 (others retired at 25 years age: Pintail now 29 years) • 4 of 5 of the first design abandoned and scrapped due to runaway corrosion in double hull features (as warned by 2001 Report to GPI) and confirmed, when it occurred, by internal “whistle blower”

15. Marine INF Nuclear Emergencies • Data increasingly hard to aquire (very little transparency) • INF 3 ships: • 10 year period 20 reported “incidents” involving INF carriers, • 12 in UK waters, including 1 near miss (at sea), 2 collisions (in harbour), 5 fires (3 in 1999), burst lube and fuel pipes in engine room, greasy rags etc • No info provided regarding cargo at time of incident • INF 2 “Atlantic Osprey” : disabling engine room fire March 2002 • May 2002 engine breakdown on 3 occasions during 22 hour period : vessel drifts (out of control) across busy Irish Sea Traffic Separation area • Atlantic Os’ not carrying nuclear materials at time of incident

16. Collision scenario • 2009 “Kapitan Lus” (small containership carrying pelleted and powdered U02: IMDG 7) through Kattegat choke point: • Collision with methanol carrier, holed beneath water line (fire narrowly avoided) • Potential Outcomes: • Fire (atmospheric plume of rad’ mats), • loss of steering, sinking, grounding,breach of cargo hold, damage to cargo, rad’ mats marine pollution

17. MV KapitanLuss : cargo of enriched U02post collision with methanol tanker in the Kattegat choke point: (high human pop & traffic density): both vessels piloted, very close to ports of refuge, high fire/explosion risk: potential for major radiological incident very high

18. Some other maritime IMDG incidents • “Mont Louis” 1984 : RoRo/container ferry. Sunk (North Sea) August 25th following collision. 60 drums (12 tonnes) Uranium Hex’ spilled from vessel : Smit Tak salvage effort begins but delayed by bad weather. Wreck begins to break up. Salvage not completed until 4th October when all “drums” reported recovered (some from sea bed and some from Belgian coast).Reported “no significant” release of radioactivity • “SS Ardlough” 1986 : deck cargo of alpha emitting Californium lost in storm (Irish Sea): not recovered • “City of Manchester” 1999 : 10 tonnes fissile UO2: engine room fire, vessel drifts out of control in busy Irish Sea shipping lanes (tankers etc) , fire extinguished but vessel requires tow to nearest port (Milford Haven: Nuclear Free Port in a Nuclear Free Local Authority) • Kapitan Lus : July 2009: container ship carrying UO2 collides with methanol carrier in Kattegat, fire narrowly avoided. Kapitan Lus holed below water line but proximity of port prevents sinking.

19. Marine High Risk Areas (MHRAs) • MHRA’s recognised and id’d by Lloyds/MCA/IMO etc • Based on analysis of shipping casualty stats • Scrabster/Barrow and Scrabster/elsewhere-in-Europe routes lie within the N.E. Atlantic MHRA: identified as one of the worlds 8 most high risk areas • Major cause of shipping “total loss” in the NE Atlantic MHRA are • Foundering (179 in a 5 year period) • Stranding/wrecking (148 in a 5 year period) • Collisions (61 in a five year period) • N:B: Nuclear submarine activity on Scrabster/Barrow route!!!!!!!!!

20. Emergency planning for INF spill • UK NCP for Marine Poll hands over SOLE responsibility for emergency response and planning to INS/NDA/PNTL (no transparency) • UK MCA, EMSA, IMO have not seen THE PLAN • Local Authorities may use NRPBs 2002 National Arrangements for Incidents involving Radioactivity (NAIR) now operated through HPA….. • “long stop” to other emergency plans when “pre-arranged and well-intentioned contingency plans fail to function satisfactorily or prove to be inadequate” • But NAIR plans make very little reference to marine/coastal scenarios 4 or 5 LINES ONLY (LESS THAN CANAL AND RIVER EVENTS!)

21. Summary of Coastal Local Authority RADIOLOGICAL Considerationsin the event of a maritime nuclear transport accident • Monitoring:to establish range: spread: diffusion: dilution: secondary sources (fall/wash out) • Monitoring/analysis to establish levels of contamination of marine, inter tidal and terrestrial environments • Monitoring/analysis of foodstuffs, drinking water, atmosphere, human environment, amenity sites (beaches etc) and ecology • ID and assess human dose pathways (ingestion/inhalation) • ID strategies for prevention/mitigation of exposures : harvest and consumption bans/closing orders: evacuation: movement restrictions (humans and livestock): PERSONAL PROTECTION : • Decontamination and disposal of wastes • ID/implement strategies for mitigating socio-economic impacts

22. Potential Impacts of INF 3 accident Public Health issues: • Sea to land transfer of marine rad: atmospheric plumes; • inhalation doses, contact doses, dietary doses, • Possible evacuation, decontamination • stress/fear/depression • Economic issues: • Closure (major/prolonged) of fisheries and amenity coasts: • (loss of income fishing and tourism) • Loss of income (major and prolonged) from coastal zone (terrestrial) agricultural/horticultural produce (as in Breton oil spills) Social issues • Major societal disruption and pressure due stresses from health, financial, employment issues

23. Tim Deere-Jones Marine Radioactivity Research & Consultation timdj@talktalk.net Tel: 01834 871 011