The Environment Agency Presentation
to the Devonport Local Liaison Committee Meeting on 16 July 2003

1. The Agency
   
   
   • is responsible for granting approvals, authorisations, variations and revocations under RSA93, for the disposal of radioactive wastes.
     
     
     
2. HM Naval Base
   
   
   • HMNB is in the process of making an application for new reduced limits for transfers to DML, and for disposal of vLLW.
     
     
   • Approval issued to transfer Project Omen Waste from Devonport to Shanks Chemical Services at Hythe, for disposal by incineration.
     
     
   • Work is scheduled to start in September to dispose of the arisings and it is anticipated that this work will take approximately two weeks to complete.
     
     
   • Joint inspection with the Naval Nuclear Regulatory Panel and NII for the handling and storage of radioactive sources. Concluded that HMNB had a satisfactory system for receipt and transfers of RA materials to and from the stores and record keeping was satisfactory and kept updated
     
     
     
3. Devonport Royal Dockyard Limited (DML)
   
   
   • Monthly reports on progress of the HMS Vanguard refit process
     
     
   • Monthly Discharge returns
     
     
   • Agency Visits to DML
     
     
     
4. Compliance Classification Scheme
   
   
   • A non-compliance, which has a potentially major environmental effect, will be assessed as a CCS Category 1.
     
     
   • A non-compliance, which has a potentially significant environmental effect, will be assessed as a CCS Category 2.
     
     
   • A non-compliance which has a potentially minor environmental effect will be assessed as a CCS Category 3 and
     
     
   • A non-compliance, which has no potential environmental effect, will be assessed as a CCS Category 4.
     
     
   • In accordance with its Compliance Classification Scheme, the Agency sent a formal warning letter to DML in April 2004, regarding a non-compliance with certain conditions of the radioactive waste disposal authorisation, issued by the Agency under RSA93.
     
     
   • The non-compliance arose from the failure of DML to follow its operating procedures rather than any exceedance of numerical discharge limits, nor did it have any radiological or environmental impact
     
     
     
5. New Application for transfer of RA Waste
   
   
   • DML is progressing an application to transfer low activity oily wastes from DML to another operator for disposalAgency will place the application on public register and will consult relevant local authorities and statutory consultees
     
     
     
6. Devonport - Habit Survey
   
   
   • The Agency, the FSA and the HSE-NII are collaborating on a 5 year long programme of habit surveys around the main nuclear sites in England and Wales. The work is being carried out by CEFAS.
     
     
   • Site-specific survey has recently been carried out around Devonport
     
     
   • The Survey addressed all parts of the environment that might be affected by discharges from Devonport. Included consumption rates of all local farmed foods and locally caught sea fish, occupancy near the site, use of beach areas and houseboats, and workers at local sewage works that treats wastes from Devonport
     
     
     
7. Discharge Returns
   
   
   • Monthly and annual rreturns show that DML has been complying with the conditions and limits in the authorisation
     
     
     
8. Tritium in the River Tamar
   
   
   Input of tritium occurring due to natural, cosmogenic and fall-out has been calculated. Data used mean river flows, ave. rainfall & input from main tributaries ( Flow 1 x 10⁹ m³ annually).
   
   
   • Typical Tritium flux to Plymouth Sound from the Tamar and tributary catchments is therefore 1 to 3 Terabecquerels/year (TBq/year).
     
     
   At the new discharge limit of 700 gigabecquerels/year, the DML contribution would be between 20 and 58 % of the naturally occurring tritium flux
   
   
   

   The graph below shows comparison between tritium activity concentrations in water
   and discharge from DML at the new tritium annual discharge limit of 700 GBq/year