N-Base Briefing 431 9th October 2004 ISSN 1478-4661
It could also mean the regulatory authorities will be forced to consider reducing marine discharges from Sellafield and other sites to bring contamination levels down to below the new guideline limits.
The Food Standards Agency has announced a public consultation on levels of radiation that should be allowed in all foods in international trade at all times - not just following a nuclear accident. The Codex Committee on Food Additives and Containments (CCFAC) is considering new international guidelines and all International Atomic Energy Agency member states have been asked to comment.
The FSA says the main impact of the proposed guidelines would be on shellfish and seafish . Monitoring results for 2003 show that levels of plutonium 239 and 240 and americium 241 in all shellfish harvested from Kirkcudbright on the North Solway coast down to the Riddle Estuary at Preston would exceed the new levels and would have to be banned for being marketed. Levels of Tc-99, C-14 and H-3 in flatfish and molluscs in the Cardiff Bay area would also exceed the new guideline safety levels.
The FSA comments that the proposed levels may be too strict, given the eating habits of local consumers and may not be proportionate to the actual risk to critical groups.
Upland sheep contaminated from Chernobyl in parts of Wales, northern England and southern Scotland would also exceed the new levels - but the UK is already using the proposed levels in controlling movement of these animals.
EU limits for caesium 134 and 137 in imported agricultural products may have to be increased as the current limit is 600Bq/Kg - while the new guidelines recommends 1,00Bq.
The FSA comments:
"In a number of areas of the UK shellfish and some flatfish have levels of radioactivity in excess of the proposed guideline levels. This could prevent marketing of these products for international trade, even if it could be demonstrated that the foods only constitute a small percentage of diet...."
"...If the EU move to implement these levels for internal trade, this would prevent marketing within the EU. Although the proposals allows for national countries to set their own limits for internal use, the UK would be bound to act by EU laws and so may have to prevent food exceeding the limits being marketed..."
"...If these new levels were adopted the Agency would be required to use them as the basis for estimating whether current or proposed discharge of radionuclides from nuclear sites could lead to food exceeding these limits. Our preliminary assessment suggests that short term discharge limits at some sites could result in a predicted concentration in foodstuffs in excess of these levels..."
The FAS consultation lasts until 29th October and details can be found at www.food.gov.uk/foodindustry/consultations/ukwideconsults/
The announcement by the UKAEA was confusing and poorly explained. Hidden behind the press releases was the decision on the public consultation on the end state of the shaft. The UKAEA said decisions on the final state of the shaft and the surrounding rock would affect how the shaft was to be emptied. It therefore carried out a full public consultation on how the shaft and the rock should be left and this ended in February. The latest announcements seem to mix up conclusions drawn from the public consultation with decisions on how to empty the shaft itself.
Shaft End State Consultation
In the unannounced conclusion of the Shaft End State public consultation the UKAEA now says it accepts a final decision will have to be left until after the shaft is emptied - the reverse of its initial position. The UKAEA received 32 responses to the consultation from its 800 stakeholders and the general public.
The UKAEA says while 'natural attenuation', or the doing nothing option, remains the preferred option, it also takes "particular note that sole reliance on natural attenuation was not acceptable in the opinion of some stakeholders and additional intervention was required" involving some additional "in situ immobilisation".
The UKAEA has therefore taken on board widespread feeling that dealing with contamination remaining after the shaft is emptied by just leaving it to decay naturally - the natural attenuation option - is not acceptable.
As a result of the consultation the UKAEA says it has decided to seal off the shaft by pumping grout down boreholes as the method of isolating the shaft - although this was never one of the options presented in the consultation. The GBP16million contract to drill the 400 boreholes and pump in the grout has been given to Ritchies, the geotechnical division of Edmund Nuttall.
Confusingly the UKAEA seems to offer no conclusions from the public consultation on what to do about contamination in the so-called 'Far Field' - where there is contamination in rocks both on shore and under the seabed.
Among the responses in the consultation the government advisors on the Radioactive waste Management Advisory Committee (RWMAC) were critical of the information provided and the way the Best Practical Environmental Option study had been prepared. The advisors say they are unable to answer some of the questions posed by the UKAEA because of lack of information. RWMAC also says stakeholders should have been involved earlier in the BPEO study.
The Committee on Medical Aspects of Radiation in the Environment (COMARE) was also critical of the lack of information provided by the UKAEA and called for the earlier involvement of stakeholders. COMARE also notes that in the BPEO the various options are 'scored' primarily on engineering issues and says potential effects on the environment need greater consideration.
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