Key Issues for the Nycomed Amersham License decision-making
The first stage of a modern consultation process is to define the issues.
The Environment Agency, Wales' public meeting was said to have this aim, but could only start the process. Various key issues proposed by local community and environmental groups are listed below. Most important is the procedure by which they are addressed and the process by which they are to be finalised, not by officials but by discussion and agreement. Many of the issues relate to health and we propose that they be covered by a Health Impact Assessment such as promoted by the National Assembly.
Procedure for public consultation
Environment Agency, Wales aims to meet the Assembly's requirement for an open and accessible consultation process, and negotiates over it with objectors and concerned bodies.
Human Rights Act
*will the Agency change future practice to accord a fair hearing to opposition views and representative organisations?
*a compilation of the principles for the licence decision is needed, to be subject to consultation and amendment. This should include the policy for reduction of discharges to an absolute minimum.
*a summary of the key reference documents and relevant considerations in relation to sustainable development, including the Welsh sustainable development scheme.
*Environment Agency, Wales to accept that the 1992 OSPAR policy applies, which means a) that criteria for harm to nature have to be determined (with the precautionary principle covering uncertainty), and b) that the present review needs to make up for past failure of action by year 2000
*that account should be taken of the information and considerations of the case ('petition') at the European Parliament over Nycomed Amersham's Cardiff operations.
*that Environment Agency Wales requires the company to supply all information necessary for a full review
*that the company be required to produce studies towards defining the "background values" of tritium, C-14 and other relevant radionuclides, and of the contributions from further discharges in the Severn, and so that the license can be judged in terms of progressive reductions to meet the OSPAR obligations
*that the company be required to compile data on the wildlife at risk and sponsor studies to assess potential effects to conform with the Habitats Directive
Risks and Hazards
*What are the Environment Agency, Wales doing to investigate the 'dose theory' of the nuclear industry and the strong scientific criticisms of it, plus how are they addressing public distrust and non-acceptance of the licence alterations?
*How are the Environment Agency, Wales addressing radiological harm, and potential genetic harm?
*Are radiological dose and 'dose constraint' inappropriate for Tritium and Carbon-14?
*Can Food Intervention Levels (of 1250 Bq/kg) be applied for Tritium and C-14?
*The public require a fair assessment concerning radioactivity and health, but given Bro Taf Health Authority's past bias to the company and the nuclear establishment, how can the public trust their assessments?
*EA Wales should publicize a scientific paper to refute Hugh Richards' work that showed correlation between tritium emissions and male perimortality, and should cooperate to secure a trustworthy re-assessment?
*The company should be required to submit technical and BPEO (Best Practicable Environmental Option) comparison of alternative waste storage and disposal options, including the building of a "decay store" as the Lords' Select Cttee recommended.
*The company should be required to submit a "concentrate and contain" alternative waste strategy, including comparative costs, pollutants and hazards with discharge and recycling options.
*The company should be required to submit proposals for waste minimisation, including substantial replacement of slit-box by glove-box handling.
*The company should give information on their products by class, and on whether some can discontinue like those of OCD because alternative non-radioactive techniques exist or are under development.
Public checks and Monitoring
*can the Environmental Monitoring programme be changed to a professional checking and investigative service, eg. by an independent consultancy answerable to the community and National Assembly?
*why should Nycomed Amersham use the Official Secrets Act ? And if they continue to do so, does this justify extra monitoring measures paid for by the company ?
*to check on excessive discharges and unreported radiological incidents and spillages, can we have
*records which are accessible to the public
*increased automatic sampling and checking by an independent contractor
*increased staff-time and checking by Agency officers in close liaison with the community?