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Sundheds- og Forebyggelsesudvalget 2014-15 (1. samling)
SUU Alm.del Bilag 122
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BOMA COMMENTS and QUESTIONS

03 November 2014

The following points underscore some of BOMA´s additional findings from the our

analysis of some of the points made by studies funded by the Danish Government

related to the risks associated with transportation of the radioactive material from

the Risø Depot and the surprising failure of those reports to even mention several

critical issues associated with disposing radioactive waste. The points mentioned

below and the results from our analysis of other issues associated with the waste

disposal process raises serious concerns about the Danish Government´s lack of

objectivity. We are also disappointed that the government has invested our tax

monies to finance superficial consultancy reports that ignore key assumptions in

their models, fail to take into consideration some of the most critical risks in those

models and the radioactive waste disposal and that lack the necessary robustness

that is required to protect the present generation and those who are not yet born.

We also find it appalling that the Danish taxpayers are put in a situation in which

they now are thinking of having to spent their own personal funds to look for an

objective and neutral analysis of the studies funded with our tax monies, in order to

get the attention of the Danish Government and the EU about the serious technical,

administrative and procedural errors in the government´s efforts to ensure that

waste is buried in the country´s poorer kommune´s that already face serious socio-

economic problems.

Our points and the associated questions that are relevant to our findings are

outlined below:

Sundhed

sstyrelsen´s

RADTRAN Transportation Risk Model

Sundhedsstyrelsen (2011) presented a report on the analysis of the transportation risks

associated with moving the radioactive wastes from Roskilde to the other potential waste

disposal sites.

First, and most fundamentally, the RADTRAN model used to estimate the risk of an accident

violates its own assumptions. Furthermore, it fails to mention that each time the waste is

transported (taken out of the depot, loaded onto a truck and trailer, driven to the site,

offloaded, placed on a boat if Bornholm is selected, and then offloaded and stored) the

transport process has an estimated risk. This means that it is totally erroneous to consider

the entire transport process as a

single

risk event. Thus, the model failed to take into

account the probability of a ship running aground under different wave, wind and other

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weather conditions, nor the risks associated with the individual probabilities of an accident

each time the waste is moved from one type of transport system to another (e.g., road, rail,

sea and road again). This rabies a question that asks -

If this radioactive waste is completely

safe, why do you have to move it anywhere. Can’t you dispose it in the place it was originally

created? If it is so safe, why does the preferred sea transportation option recommend that the

waste be transported on a barge where no people would be onboard, but rather on the tow

boat that pulls the barge?.

Given the low probability that the RADTRAN model shows for a transportation accident, we

would like to refer the government to a recent accident by a Danish ship carrying

radioactive wastes in Scottish waters (see the box with details below). To ignore this is

irresponsible on the part of the government.

Dozens evacuated from oil platform after ship carrying radioactive waste catches fire in

the North Sea and drifts towards it



Fire broke out last night in one of the funnels of Danish-owned MV Parida

Ship was carrying processed radioactive material from Scotland to Antwerp

Crew shut down the ship's engines and it began to drift towards oil rig

The Beatrice platform lies 15 miles off Wick on Scotland's north east coast

All 52 members workers on board lifted off by helicopter and taken ashore

Parida was towed to Cromarty Firth where it dropped anchor for repairs

Lang Banks, director of WWF Scotland said:

'This incident highlights the problems of dealing with the hazardous and

expensive radioactive mess that the nuclear industry always leaves in its wake. 'Given all the severe weather warnings,

questions need to be asked as to why a vessel carrying radioactive material was at sea at all.'

http://www.dailymail.co.uk/news/article-2785254/

QUESTION #1: After: a.) signing the Convention on the Protection of the Marine

Environment of the Baltic Sea Area, 1992 (HELCOM [1992]), in which the Contracting

Parties undertake actions to prevent and eliminate pollution of the Baltic Sea Area caused

by harmful substances from all sources and from land-based sources, and b) investing

millions of Danish kroner from taxpayers to support actions to reduce pollution to the

Baltic (e.g., Port Waste Management Reception Facilities) under the DANCED program in

the 1990s, how can the present government justify transporting toxic waste across the

Baltic and risk further degradation in the case of an accidental spill during shipping?

We can assume that will answer by saying “We have taken this seriously and we do not

consider there to be a risk, as shown by the results of our mathematical transport risk

model"...

Our next question asks for them to demonstrate that their transportation risk model. I believe

that it has some potential flaws that raise many questions about the validity of their model.

These two questions raise concerns our about the risks and thereby violate the Precautionary

Principle, which the Helsinki Convention explicitly invokes for all waste that is transported or

released into the Baltic. However, before we send them off, we need to do our homework and

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take

closer

look

the

transportation

modeling

results.

QUESTION #2: We would like to know why there are no assumptions listed for the

application of the RADTRAN transportation risk model (Sundsstyrelsen [2011] While we

will run our own analysis of the results presented in the model, we would like to request

that an independent, peer review of the results be carried out and financed by the

government.

QUESTION #3: We find it odd that the RADTRAN model treats the worst case scenario by

lumping all of the estimated 10 trips, rather than analyzing each event as a separate risk

event. As a result, we would like to request an independent review of the risk associated

with each of the 10 trips which will require loading the material onto a forklift, a container

truck and a barge, transporting it ten times across the Baltic, offloading it to land and then

offloading it to the repository site.

Rambøll Scoping Report

The brief paragraphs that follow outline general and specific issues related by Rambøll`s

weak attempt to defend the Danish government’s case for the transport, disposal and

storage of: a) short-lived waste; and b) 233 kg of high level “special waste” is

disappointingly superficial. The scoping components it presents are incomplete and the

report obfuscates several critical issues that Danish society and its elected representatives

must have in front of them in order for them to make better-informed decisions. Curiously,

the joint report by Rambøll and the Danish Ministry of Health ignores several other studies

(also funded by Danish taxes), which contain important information.

General Comments

The Scoping Report presented to the public by Rambøll and the Danish Ministry of Health

raises some concerns related to credibility, because the Report

fails to:

1. Identify the

magnitude

of the potential impacts identified by the scoping analysis.

2. Examine possible

synergies, or cumulative effects

that can create a metaphorical

“chain reaction” of negative social, economic and environmental impacts that would

not happen without the project.

3. Mention the

trans-boundary nature of wastes

associated with the project. This is

particularly important for the Bornholm site under consideration, given that it is

surrounded by at least three countries (Germany, Poland and Sweden).

4. Examine the

reversibility/irreversibility

of the environmental and social impacts

associated with the project. It also ignores whether the impacts fr the different

scoping components are temporary or permanent.

5. Include the

Precautionary Principle

in its analyses, even though this is a central

principle related to uncertainty that most governments have ascribed to since the

Rio Conference on Environment and Development in the 1990s.

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Based on the above, the report does not contain the degree of robustness that one would

expect from an elected government who has a constitutional responsibility not only to

protect present generations, but future ones as well. While there are likely to be many

explanations for this situation, we recognize that in the consulting world, profits are the

gold standard and large consulting firms rarely work for more hours than are allocated by

their clients. Consequently, the superficial nature of the report might be because the Danish

government under-estimated the time required to produce a robust report (of course, this

raises additional concerns about competence), the lack of an eye for detail by the

consultant, or that the Report`s authors simply found some inconvenient truths that might

not be palatable to the public. Regardless of the reasons, we consulted one developing

country that has received considerable capacity building in the field of environmental

impact assessments financed with Danish taxes through Danida. The director of

Environmental Permitting stated that Ministry would reject the report for many of the

reasons described above and particularly because of the lack of transparency on the part of

the government and tis consultant.

PECIFIC

OMMENTS

In addition to the general observations, there are several specific points highlighted below.

Transportation Risk Model

The Rambøll study does not mention the risks associated with transporting the national

inventory of radioactive waste from Risø to any one of the six final Danish repositories.

There is no mention of the Transportation Risk Model

(

based on calculations of potential

doses using RADTRAN, a computerized algorithm used worldwide) that was applied to the risks the

associated with rail, road and aquatic transport of the

Risø-produced short-lived waste or the

233 kg of high level “special waste”.

It is unclear why

the report assigns a single risk to the entirety of trips required to transport the

material – the risks for each trip in which the transported waste travels by rail, land or sea is

independent

of other trips. Furthermore, the report fails to state explicitly that

the

risk an accident

is exactly proportional to the distances involved.

Instead, it uses unclear language that

detracts from this important point.

The report also highlights that the risk of radiation exposure to the crew is not negligible

and they recommend that the waste must be transported on an un-manned barge and that

the crew should wear protective clothing. This is not very reassuring when the government

repeatedly states that the waste is safe (“

In terms of exposure to radiation; persons, other than

the crew, will not get exposed to radiation along the route, and the crew may be placed relatively

far from the waste packages depending on the configuration of tug and barge.”). The report goes on

to say there is a disadvantage to the boat transportation of the wastes because the unloading and

loading of packages from barges to trucks is an operation that must be considered when estimating

Sundhedsstyrelsen (2011). Radiation doses from the transport of radioactive waste to a future repository in Denmark: A model (URL:

http://www.sis.dk).,

56 pp.

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doses of the transport on barges as the workers involved can be considered to be exposed to

radiation. Hence, when estimating the method of road transport only the actual transport is

considered, while when estimating the method of sea transport, not only the actual transport by sea

must be considered, but also the handling and the subsequent transport by road must be included.

Gas Emissions at the storage site.

Rambøll fails to mention a report by COWI (2009) stating that

gases would be

formed when the

waste gets into contact with (ground) water and decomposes, as described in the Pre-feasibility

study for final disposal of radioactive waste. Disposal concepts prepared for DD by

COWI

(May2011, attached to this email). The gases would have to be released through

300 O

HDPE ventilation pipes with an above ground discharge, which is protected against intrusion.

Exposure pathways related to air borne nuclides of concern for the long-term impact primarily

include a) Inhalation of gases and b) External exposure. The COWI study only examines the

doses for adults and did not measure the risks for children, but recommended that the

radiation risks to children should be conducted in subsequent studies. Rambøll presents no

information on the risks that the emitted gases present to the entire population in the area of

direct and indirect impacts.

Loss of property values due to the fear of the unkown

IT is truly amazing that there is no mention of the potential loss in land and home values

that will take place in nearby areas of the selected radioactive waste disposal site. We are

currently working with volunteers to make the loss of property values associated with such

an extreme decision by the government and once again, we are forced to do this because

the government has not gone beyond its superficial reporting that was made by its hired

consulting companies

Tourism

Although the Scoping document correctly mentions that there could be impacts on tourism

from dumping the material on Bornholm, it makes no in-depth analysis of the lost tourism

revenues and job losses from the more than one-half million tourists from all over the

world that visit Bornholm each year. It also fails to mention of how this will affect

Denmark's image should the government decide to place radioactive waste on Denmark’s

largest tourist destinations and the place in Denmark with most natural areas.

Contingency Planning

It is unfathomable that the report makes no mention of the need to develop a special

contingency plan in the event of a waste-material transportation or other type of accident

on Bornholm, given the limited access that people who are accidentally exposed to severe

radiation doses to the mainland. Would a special boat be assigned to ferry badly injured

victims? What alternative would be employed if an accident occurred during one of

Bornholm`s many, severe winter storms?

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Faults in the logic and arguments in their risk assessment

Do you believe that the transport risks are equally weighted across all modes of transport?

Do you believe that the transport risks by sea are increased in differing weather

conditions?

Can you point to me in your report where you asses the risk of transportation by sea under

high waves, high winds, sudden storms etc.?

If an accident were to take place at sea during transportation would this only affect

Bornholm or would other countries be affected by this for example Sweden, Germany or

Poland.

Are you aware that the Helcom convention says that any country transporting hazardous

waste that could affect the rest of the Baltic has to pass this information to the other

countries involved?

Why was no mention of this convention made in your report and the time and extra cost

that will be involved in getting agreement and following the correct legal procedures laid

down by this international convention

If other countries might be affected by an accident of this nature do you legally have to

undertake any extra consultation with their governments for this kind of dangerous

transportation of materials across international waters?

Can you show me specifically what EU directive states that the country that produces the

waste has to dispose of it within the same country.

Types of Radioactive waste.

In your report you refer to radioactive waste. You make no mention to the types of

radioactive waste involved, can you specify exactly what types of radioactive material will

be involved and where this waste was produced.

Will there be any Uranium, Cesium, Plutonium.

If Uranium were to be leaked accidentally in a transportation accident like in (Give

examples of radiation leak) how many years would this radiation contaminate the area.

How many people would be expected to develop serious health issues as a result of this?

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Ask the same question for each type of radioactive waste.

If there is more than one kind of radioactive waste, do you agree that the risks of each type

or radioactive material are equal.

If the types of radioactive waste are not the same then why have you not given each type of

waste its own risk assessment and instead just grouped them under a single heading and

given them the same degree of risk.

Interrelationship of the issues you addresses in the report.

Your report covered these specific issues – 1,2,3 etc., but from my impression you seemed

to compartmentalize them and address each issue separately. In my understanding many of

these issues are interrelated. Can you explain where in your report you showed how these

issues connect, affect and interact with each other.

Groundwater

Health issues

Depreciation of land values

Impact on tourism

Transportation risk

Depth of storage

Radioactive waste that will be around for thousands of generations

TRANSPORTATION RISK

If this radioactive waste is completely safe, why do you have to move it anywhere? Can’t

you dispose it in the place it was originally created?

Why can’t you move it to the facilities available in Sweden, Spain etc?

The normal facilities that deal with radioactive waste currently bury it 1000m

underground. According to your report the radioactive waste will be buried on Bornholm

at a depth of 45? meters. Are the other countries who have experience in dealing with

radioactive waste digging their holes unnecessarily deep if you believe it is safe at a depth

of 45 meters?

Can you show me your risk assessment based on the depth of burial of radioactive waste

and the likelihood of contamination and escape.

The need for experts to talk together and debate the issues publicly rather than a

single person putting together the report and biased to their own sepeciality

Do you agree that most impact assessment are subjective?

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If the experts were put together and asked the same questions we are asking today, do you

think there is a possibility that there are some issues they might discover that you have

missed in your somewhat limited and superficial case study.

Have you invited any other independent European experts to this meeting today who are

not being paid by the government?

Partsindlæg fra medlem af BOMA og borger på Bornholm

Joe Ryan