A conflict of nuclear interests

The UK’s nuclear security and safety watchdog faces what shocked industry insiders are calling “unbelievable” conflicts of interest, The Independent reported on 27 May. (http://www.independent.co.uk/news/business/news/exclusive-nuclear-regulator-the-onr-accused-of-indefensible-conflict-of-interest-9437012.html)

The newspaper reported that The Office for Nuclear Regulation (ONR) is receiving technical advice from several of the very companies that it is supposed to be monitoring, including the US engineering conglomerate Jacobs and the Ftse 100 stalwart Amec. This has led to accusations that the advice cannot be viewed as independent. ONR inspects nuclear sites across the country, including the Atomic Weapons Establishment (AWE) in Berkshire and Hinkley Point civil energy reactors in Somerset. It recently issued formal cautions to two workers on Cumbria’s Sellafield, one of the world’s most complicated decommissioning sites, for an incident that could have exposed themselves or their colleagues to heightened levels of radiation.

But there are fears that ONR’s efforts to oversee these hazardous sites could be compromised by contracts it has dished out for technical support in its assessment work. In early April ONR handed Jacobs a five-year deal to help the watchdog in areas like assessing external hazards and decontamination in relation to its work on existing nuclear sites and future reactor designs. Amec gives advice on complicated issues such as reactor chemistry and radiation protection, while the consultancy Arup and building firm Sir Robert McAlpine help on civil engineering issues. All have extensive nuclear interests in the UK.

Jacobs is part of the consortium that owns AWE, which builds and maintains the UK’s nuclear defence deterrent, Trident. Amec is in the consortium looking after the clean-up of Sellafield. Both of these huge firms are supporting Horizon Nuclear Power with engineering expertise on proposed plants at Wylfa on the Isle of Anglesey and Oldbury in south Gloucestershire. Arup worked for the operator RWE Npower on assessing potential sites for new nuclear power stations in Cumbria. Sir Robert McAlpine built 13 of Britain’s nuclear plants, such as Sizewell B in Suffolk.

I am accurately quoted in the article as saying: “It’s so obvious that this is a conflict of interest, it’s such a straightforward conflict of interest. This is indefensible.”

 

I wrote to the ONR in April asking them to explain how companies can both support the nuclear industry commercially and suort the industry’s regulator as  contracted consultant. Here is what they told me in reply. I am unconvinced.

 

Dr Lowry

 

Thank you for your query regarding potential conflicts of interest with a contactor within ONR's Technical Support Framework. 

 

I would like to reassure that ONR is fully aware of the need to ensure the independence and integrity of its regulatory activities and decisions.  ONR relies on Technical Support Contractors (TSCs) to undertake assessments and we recognise that the industry itself is also utilising the TSC pool to support its own activities.  However, ONR would not tolerate a situation in which a person carrying out assessment for ONR is also working on a related matter for a current or prospective licensee. 

 

My staff take steps to ensure that regulatory independence is not compromised when using contractors within our Technical Support Framework (TSF) and the industry itself is also acutely aware of the need to avoid potential conflict of interest where TSC's are used.  As a pre-condition for ONR's selection of a TSC, we seek assurance that the TSC has robust internal management controls which prevent conflicts of interest from occurring and the TSC's responsibilities with regard to potential conflicts of interest are included in the contract that allow it to become part of the TSF. 

 

With regard to your comment on "objective regulation", a TSC will be asked to carry out specific technical assessments for ONR, but the scope and objectives of the work are specified by ONR, and TSC outputs and conclusions are considered by suitably qualified and experienced ONR Inspectors.  I am satisfied that where TSC's are used, my inspectors maintain oversight and control of the work and are readily able to take intelligent ownership of the reports produced and to interpret the associated conclusions.  Please be assured that ONR inspectors will continue to make the regulatory decisions and issue the permissions necessary for us to effectively regulate the duty holders and ensure the continued safety and security performance of the industry.  This will never be the purview of the TSC. 

 

Should a potential conflict of interest emerge, we have a clear protocol that provides a robust process and defines clear criteria against which the emerging conflict can be judged.  It ensures that we can demonstrate to others that our suppliers are sufficiently impartial to provide support to civil nuclear regulation.  However, ONR reserves the right to terminate the Contract immediately by notice in writing and/or to take such other steps it deems necessary where, in the reasonable opinion of ONR, there is or may be an actual conflict, or a potential conflict.    

 

ONR will continue to be committed to its policy of openness and transparency as part of its regulation of the UK nuclear industry, this includes the publication of Project Assessment Reports (PARs) written in support of our regulatory decision making, these PAR's will reference all relevant documentation in support of the decision, including that produced by TSC's.  We are also very open on which organisations form our TSF and where we are utilising them.

 

I believe that ONR has robust arrangements in place to protect against conflicts of interest arising within the TSF and I trust that the evidence I have provided allays your concerns in this area. 

 

Regards

 

 

Mark Foy

Deputy Chief Inspector & Director 

ONR Civil Nuclear Reactor Programme

24 April 2014

Green talk in Europe's greenest city

What more can you do you do as mayor of the greenest city in Europe, to make further sustainable progress?

So, last month, Dr Dieter Salomon, Green Party mayor of Freiburg in the Black Forest in southern Germany, hosted the third Convention of over 100 Global Environmental Laureates, myself included, in his super-sustainable city, a long term leader in solar energy installation, waste and resource upcycling, and sustainable  construction. (www.freiburg.de/greencity)

At the convention, attended German academic entrepreneur Dr Winfried Hoffmann of Applied Solar Expertise (ASE) in Germany predicted a total solar revolution by 2050; while Dr Ahmet Lokurlu, the CEO of SOLITEM Group, based in Turkey, Germany& USA showed how solar based cooling has already been Implemented in Cyprus, Mexico, and Turkey (http://www.european-environment-foundation.eu/text/103/en/convention-2014.html)

Another contributor cited the ominous words of Xie Zhenhua, China's chief climate negotiator: "If we allow China's per capita carbon emissions to rise to US levels, it will be a disaster for the world."

Perhaps the most compelling contribution came from an international green  businessman, Günter Pauli, founder of the zero energy resources (www.zeri.com) and advisor to the United Nations University in Tokyo. In his presentation “Blue Economy”  called on “each and every one“ to develop ideas to bring about positve economic change, and was evisceratring in his criticisms of waht he   considers the  negative economic models promoted by the giant global business schools at Harvard, Stanford and INSEAD, in Paris. 

The $313 billion consulting business is molding corporations to do more of the same, while the present crisis requires something much better, he argued.

He stresses a glass is never half full or half empty: it is always full - part liquid, part air.

Dr Pauli has some intriguing views on sustainable construction and materials use.In 2000, at theWorld Fair in Hannover, he organised the building of a vast pavillion using only bamboo as structural material, based on carbon neutral concrete. He advocates growing your own house, in certain developing world contexts!

He also has ideas for re-use of demolition rubble, demonstrasting how it can be made into paper products witout cellulose, and is being done so  commercially in Taiwan. The German environment ministry now uses stone-based paper Much more at www.theblueeconomy.org!

 

Radon risk distorted by pro-fracking Lords report

Last Thursday (8 May) the House of Lords Economic Affairs Committee published a 100 page report on The Economic Impact on UK Energy Policy of Shale Gas and Oil

(http://www.publications.parliament.uk/pa/ld201314/ldselect/ldeconaf/172/17202.htm)

supported  by 550 pages of written and oral evidence. (http://www.parliament.uk/documents/lords-committees/economic-affairs/EnergyPolicy/EAC-energy-ev-vol.pdf).

The report is strongly supportive of going ahead with fracking, as soon as possible. The peers clearly regard the nascent fracking industry under threat from too much environmental regulation, asserting “There is no reason why effective regulation should not be transparent and speedy as well as rigorous. Delay is not only costly and wasteful, it can also drive investors elsewhere.”

But one area where the peers are sanguine about safety worries me: the release of radon gas into the methane gas stream, when the gas is released  by fracking. I  Gave evidence to the committee on this worry, which the report records thus, at paragraph 181:

 

Dr David Lowry* told us that shale gas "would have to be stored for at least a month before being distributed to people's homes to allow for this radioactive decay of radon."[377] He cited a US report that "some shale gas deposits contain as much as 30 times the radiation that is found in normal background."[378] Professor Stephenson did not regard the presence of radon in gas as "a serious risk."[379] He told us that shales are "weakly radioactive … much less than you get in somewhere like Aberdeen or Cornwall … This is quite a well known phenomenon".[380] Public Health England's interim report took account of the US study and "considered very unlikely that shale gas activities would have any significant effect on radon levels in homes."[381] We find persuasive the view of Public Health England that shale gas development would be very unlikely to have a significant effect on radon levels in homes.

(references: 377  Dr David Lowry.  378   Ibid. The report by Marvin Resnikoff from the Radioactive Waste Management Associates is available here: http://energyindepth.org/wp-content/uploads/marcellus/2012/04/Resnikoff.pdf.)

The matter was raised in an oral evidence session with Professor Mike Stephenson, Director of Science and Technology, British Geological Survey, by Lord Rowe-Beddoe, who asked: on environmental aspects, would you care to make a comment on radon? 

Professor Stephenson responded: “Shales are weakly radioactive: something like 10 parts per million, which is much less than you get in somewhere like Aberdeen or Cornwall. There are quite low levels of radioactivity but they are radioactive. Small amounts of radioactivity can get into flowback water and into gas. This is quite a well known phenomenon in the oil industry because oil and certainly gas sometimes contain radon. Methane gas contains radon. We do not regard it as a serious risk.” 

So it is clear, Professor Stephenson asserted the BGS view of radon in methane, but did not elaborate on the scenario I painted in my written evidence, of radon-rich methane gas being pumped into the  nation’s kitchens, and being released into these enclosed spaces after the methane is burned on a hob.

For their part, the peers conclude that “we find persuasive view of Public Health England that shale gas development would be very unlikely to have a significant effect on radon levels in homes.”

But this is not what Public Health England said in its report Review of the potential public health impacts of exposures to chemical and radioactive pollutants as a result of the shale gas extraction, released in draft form on 31 October 2013. On pages 14 and especially 15, actually agrees with me on the potential hazard, stating:

“If the natural gas delivery point were to be close to the extraction point with a short transit time, radon present in the natural gas would have little time to decay….there is therefore, the potential for radon gas to be present in natural gas extracted from UK shale.”
(http://www.hpa.org.uk/webc/HPAwebFile/HPAweb_C/1317140158707).

Why would the peers come to their perverse conclusions, not supported by the source  they cite in support of their conclusions?

A Greenpeace UK energy blog last week runs an interesting analysis on the interests of the peers on the Economic Affairs Committee as follows:

“A Lords committee that  is calling for fracking to be made an urgent national priority includes at least five members with interests in the global industry - according to an Energydesk analysis of parliamentary registers. 

The report by the House of Lords Economic Affairs committee bemoaned the slow pace of the UK’s shale gas development so far and called for ministers to take a leading role in advocating development. 

The committee is made up of appointed Lords who do more than opine on government policy - holding interests and positions across industry. We thought we’d take a look at their positions and investments in energy.

Full analysis (spreadsheet).

The analysis found that one member, Baroness Noakes, holds shares in at least three firms with interests in shale gas, including British Gas owner Centrica.

Centrica

The firm has invested in Cuadrilla’s exploratory operations in the North East and - as such - could be a major beneficiary of government policy on fracking.

Noake’s other investments include Shell, BG Group & BP who have all invested in shale gas reserves in the US alongside a variety of mining and support services firms.

Fellow member, former chancellor Lord Lawson, is now almost as well known for his climate skeptic think tank, the Global Warming Policy Foundation, as his Thatcher era tenure.

Lord Lawson

Lawson states on his parliamentary biography that he is chair of the Central European Trust (CET) though company house records suggest he resigned as a director last year. 

Aside from representing BP and Texaco, both involved in shale gas, the CET advises Poland’s state owned firm PGNiG which is working with UK shale gas explorer Cuadrilla to frack in the eastern European state.

His Conservative party colleague Lord Griffiths declared during hearings his directorship of Goldman Sachs who chose today to launch their very own shale fund.

But it isn't just Conservatives with interests in shale gas. Labour’s Lord Hollick holds shares in Samson Resources which is invested in shale gas in the US. Lord McFall holds investments in FTI consulting, which advises the industry.

Crossbencher Lord Skidelsky is invested in Janus Capital, which holds stakes in oil and gas firms with shale operations and advise people to put money into the US shale gas industry.

Finally the committee includes one member with an obvious - and frequently declared - interest in government policy on energy and climate. Lord May sits on the government’s independent committee on climate change.” 

(http://www.greenpeace.org.uk/newsdesk/energy/news/who-are)

Page 95 of the report  publishes a list of the peers declared interests in energy interests.

If the other conclusions of this report are also deficient, in that they do not reflect the evidence, it undermines the credibility of this report in its entirety. Such a situation concerns me.

 

 *Fracking’s radiation risk

 

By Dr David Lowry

 

3 October 2013

 

environmental policy and research consultant

 

 

 

Along with many banners saying ‘Could you kindly Frack Off’, ‘Police say no to fracking!’ ‘For a frack-free future’, protestors at Balcombe, Sussex  in August highlighted their concerns over contamination of the local water table, fugitive emissions of fracked methane  gas that could exacerbate climate change dangers, and worries over community disruption  from many lorries  that will have to come to areas hosting fracking platforms with  toxic liquids used to flush out shale gas. 

 

Earlier this year, also in August, in an article in the Daily Telegraph, The Prime Minister, David Cameron tried counter concerns over prospective environmental hazards such as water contamination  by referring to a "stringent regulatory system." (“We cannot afford to miss out on shale gas”, 12 August  2013, http://www.telegraph.co.uk/news/politics/10236664/We-cannot-afford-to-miss-out-on-shale-gas.html)

 

Mr Cameron’s coalition partners also give cautious support for shale gas in a motion debated, and endorsed, at the LibDem conference in September 2013 saying limited shale gas extraction should be allowed, provided that "regulations controlling pollution and protecting local environmental quality are strictly enforced, planning decisions remain with local authorities and local communities are fully consulted over extraction and fully compensated for all damage to the local landscape".

 

But neither of the Coalition partners, nor indeed the protestors in Balcombe, make any mention of radioactive risks arising from fracking.

 

However, Mr Cameron’s own Health minister, Anna Soubry, has told Labour MP Paul Flynn in a written answer in May that Public Health England (formerly the Health Protection Agency) is preparing a report identifying potential public health issues and concerns, including radon (release/emissions, my emphasis)) that might be associated with aspects of hydraulic fracturing, also referred to as fracking. The report is due out for public consultation in the summer. Once released for public consultation, the report will be freely available from the PHE website.” (Hansard, 20 May: Column 570W)

 

PHE have told me they now do not expect their report to see the light before the end of the year, which is hugely disappointing considering its prospective importance to the public debate.

 

PHE is concerned to evaluate the concerns raised  over potential risks of radon gas being pumped into citizens’ homes as part of the shale gas stream. Unless the gas is stored for several days to allow the radon's radioactivity to naturally reduce, this is potentially very dangerous.

 

Radon is unquestionably the leading cause of lung cancer in non-smokers.  A report produced by the HPA in 2009, Radon and Public Health. (Report of an independent Advisory Group on Ionising Radiation: Docs RCE 11, HPA 2009: www.hpa.org.uk) states:

 

“Radon is a naturally occurring colourless and odourless radioactive gas that can seep out of the ground and build up in houses, buildings, and indoor workplaces. Epidemiological studies have established that exposure to radon is a cause of lung cancer, with a linear dose-response relationship. Exposure to radon is now recognised as the second largest cause of lung cancer in the UK after smoking and analysis for the Health Protection Agency indicates that about 1100 UK deaths from lung cancer each year are caused by exposure to radon (most caused jointly by radon and smoking”

 

 

 

Initially radon released from its virtually sealed underground locations will be in monatomic suspension, but then it accretes onto dust particles, pipework, etc, and some of it may remain suspended in the gas and come out in our cookers.

 

 

 

US concerns

 

The current concern about how much radon is likely to be piped into people's kitchens was spurred by a report last year by Dr Marvin Resnikoff, of Radioactive Waste Management Associates (http://rwma.com/aboutus.htm). Dr Resnikoff estimated radon levels from the Marcellus gas field - the nearest one being exploited to New York - as up to 70 times the average. Dr Resnikoff’s group, now based in Vermont, used be to be based in Brooklyn, New York, hence its work on shale gas being piped to New York consumers. RWMAs suggest some shale gas deposits contain as much as 30 times the radiation that is found in normal background.(http://gdacc.org/2012/01/10/radon-in-natural-gas-from-marcellus-shale-by-marvin-resnikoff-radioactive-waste-management-associates/). New scientific evidence on these concerns was published in the US journal Environmental Science & Technology in September 2013 ( “Impacts of Shale Gas Wastewater Disposal on Water Quality in Western Pennsylvania,” http://pubs.acs.org/doi/abs/10.1021/es402165b)

 

 

 

Moreover, Professor, James W. Ring, Winslow Professor of Physics Emeritus, Hamilton College in New York State (http://www.hamilton.edu/index.cfm) stresses:

 

“The radon and natural gas coming from the shale mix together and travel together as the gas is piped to customers. This is a serious health hazard, as radon––being a gas––is breathed into the lungs and lodges there to decay, doing damage to the lungʼs tissue and eventually leading to lung cancer.”

 

 

 

Radon has a half-life of 3.8 days. Using the general rule of thumb of 10 half-lives to decay to 1/1000 of original concentration, that would be 38 days, or roughly one month, depending on how radioactive it was to start.

 

 

 

Fracked gas would  thus  need to  be stored for at least a month before being  distributed to peoples’ homes, to allow for this radioactive decay of radon.

 

 

 

The Radon Council, formed in 1990, is an independent non-profit making self-regulatory body for the radon protection industry. Its formation was welcomed in the Interim Report of the Parliamentary Select Committee on Indoor Pollution, which called upon industry to provide a solution to the radon problem. The first objectives were to identify the “cowboy” operators and dubious training courses then in practice.  Later there followed a first edition of a training manual  and an agreed Code of Practice for the industry.

 

It does not seem ministers have read any of the Radon Council’s literature, so keen are they to press ahead with fracking, as the Prime Minister and Chancellor’s speeches at the Conservative Party Conference on 30 September and 2 October 2013 –backed up by the Mayor of London -  respectively demonstrated.

 

 

 

At the end of July  2013 the Communities Department published its Revision of building regulation policy on radon. In the impact assessment it explains the reason for the revised regulation is:

 

 

 

“Radon is a naturally occurring radioactive gas linked to lung cancer. Alongside a health and awareness programme and testing and remediation of existing buildings, current Government policy includes targeted intervention through the Building Regulations which requires radon protection in new buildings in areas of elevated radon risk….We intend that the Building Regulations and supporting statutory guidance is clear on current radon risks, and ensures buildings are fitted with proportionate measures to prevent the ingress of radon and thus reduce radon-related lung cancers. ”

 

 

 

It later adds “The respective cumulative risks of lung cancer [from radon exposure] affecting people by age 75 years in the UK at 100 and 200 Bq m-3 are 0.42% and 0.47% for non-smokers and 17% and 19% for continuing smokers.”

 

(https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/225640/Radon_IA.pdf)

 

It also states boldly: “The chosen policy will maintain a targeted regulatory intervention (aligned to the most up-to-date radon maps), to ensure that all buildings in higher-risk areas incorporate appropriate radon measures.”

 

In light of this clear precautionary approach, it is odd that all ministers seem to be uncritically cheerleading for expanded fracking, despite its possible radon risk.

 

In January 2012 the European Commission Energy Directorate released a 100-page report on ‘Unconventional Gas in Europe,’ primarily assessing the situation in France, Germany, Poland and Sweden. It has a section on environmental liability, but no mention of radon pollution.

 

(http://ec.europa.eu/energy/studies/doc/2012_unconventional_gas_in_europe.pdf)

 

Nuclear waste too

 

In addition, both RWMA in the US and the internationally respected Norwegian environmental consultancy, DNV (Det Norske Veritas have identified radioactive waste contamination as one problem with fracking, arising from  contaminated rock cuttings and cores to which have the potential for exposure to radioactivity on health. Risks relating to NORM (naturally occurring radioactive materials) contaminated downhole and surface equipment should also be considered, both suggest.

 

(Risk Management of Shale Gas Developments and Operations January 2013 DNV-RP-U301; http://www.dnv.com)

The Commission report also records that in Sweden, the handling of radioactive shales requires a permit in accordance with the Radiation Protection Act and the Radiation Protection Ordinance. This is the case when the uranium content exceeds 80 ppm (parts per million), it points out. This permit is granted by the Swedish Radiation Safety Authority. “Non-compliance with the permit can lead to it being revoked and, if done intentionally, the responsible person can be fined or even imprisoned,” it warns.

It adds that in Sweden, the possible occurrence of radioactive materials (NORMS), heavy metals or saline brines is taken into account by the permit for the environmentally hazardous activity, required for the disposal of waste water.

Green MP Dr Caroline Lucas, who was arrested as a result of her protesting against fracking in Balcombe during August 2013, initiated a wide-ranging Parliamentary  debate (www.publications.parliament.uk /pa/cm201314/cmhansrd /cm130718/ hallindx/130718-x.htm)
on fracking on 18 July 2013 in Westminster Hall, drew attention to the radon risk and the outstanding PHE report. She asked the minister, Michael Fallon, pointedly: “Will the Minister explain the delay in publishing this research report when the public debate over fracking is moving ahead apace?”Mr Fallon replied to several of Caroline Lucas’ questions on environmental hazards of fracking, but gave no response to her queries on radon risks. I wonder why?