A Letter to Allerdale Borough Council - Saving the "Lake District" from a High Level Nuclear Dump?

Dear Allerdale Borough Councillor Thank you for ruling out the Lake District National Park for inclusion in the “Community Partnership”. It is largely forgotten now that the Lake District of Beatrix Potter, Ruskin, and Turner would have included all of your Borough of Allerdale and all of Copeland up to the cradling arms of the Irish Sea.

Prior to the National Park designation the English Lakes included the whole of Allerdale and Copeland as posters up to the 1940s illustrated .



All of your Borough of Allerdale was, up until 2008, a nuclear free area (apart from transports of radioactive material through the Borough to Sellafield). Since 2008 the following nuclearisation of Allerdale has taken place 1. Lillyhall landfill has been opened up to “high volume very low level radioactive wastes” that is bad enough but opening the novel route has meant the inevitability of higher activity wastes “accidentally” being dumped (previously only NORM waste was dumped here in small quantities) 2. Despite the protests of local businesses Studsvik were allowed to open a radioactive scrap metal recycling facility serving the UK (and beyond?) -ownership now transferred to Cyclife/EDF 3. A radioactive laundry “Energy Coast Laundry” has been opened up providing services to the UK nuclear industry using West Cumbria’s stressed public water resource (Sellafield has its own dedicated water resources). 4. The Port of Workington is a container park for the radioactive scrap metal overflow from the metal recycling plant operated by Cyclife All of these novel routes of radioactive wastes to the environment have received either zero or minimal public scrutiny/debate/vote by Allerdale Borough Councillors. The Borough Council has incredibly now agreed to enter a “Community Partnership” with Radioactive Waste Management whose remit is to deliver a Geological Disposal Facility for heat generating nuclear wastes. With no public vote or debate Radioactive Waste Management have already drilled 16 Rock Characterisation boreholes at Drigg in your neighbouring borough of Copeland. The boreholes are the initial phase of RWM's and the “Nuclear Decommissioning Authority’s emerging Near Surface Disposal (NSD) programme. There are two main concepts being considered for NSD in the UK: at surface level and at depth, 10s of metres below the surface. Data from 400 points in and around the Repository has been collected to support feasibility studies to inform potential Near Surface Disposal (NSD) options in the future.” (On the Level LLWR Newsletter , Issue 27, March 2021). The reason to open up the Low Level Waste Repository at Drigg to Intermediate Level Wastes is to free up more room in a GDF for the most dangerous Heat Generating Nuclear Wastes. CEO of West Cumbria Mining Mark Kirkbride is a key advisor to government on delivery of nuclear waste “disposal” and has compiled the Committee on Radioactive Waste Management’s Annual Report No 3724 which details the push for Near Surface Disposal. The advice Kirkbride and CorWM have given in the last year has "been in relation to the concept of Near Surface Disposal (NSD) for intermediate level waste which is being explored by NDA as a potential solution for the disposal of specific intermediate level waste materials, reducing the volume of certain elements of the inventory into a GDF.” The plan for Drigg is to run in tandem with a GDF but to be delivered far earlier : "All work is exploratory only at this stage, however if taken forward, a new NSD facility could be available within the next 10 years.” (NSD Strategic Position Paper August 2020) RWM are keen for the public and councils to forget the fact that the rejected NIREX plan was limited to the deep disposal of Low and Intermediate Level Nuclear Wastes - the plan now is for the deep disposal of Heat Generating Wastes. Increasingly Low and Intermediate Level waste are proposed to be dispersed to the environment via novel routes such as Landfill, Metal Recycling and to the UK's LLWR at Drigg. This dangerous mission creep is not the act of a good or honest “Partner.” In a letter to “The Guardian” of June 28,’07 the NIREX Inquiry Inspector Mr Chris McDonald had stated : “The relevant geology in west Cumbria is apparently now claimed to be ‘stable, although imperfect’.…the imperfection consists of simply failing to meet the internationally agreed criteria on the suitability of rocks for nuclear waste deposit. The site should be in a region of low groundwater flow, and the geology should be readily characterisable and predictable, whereas the rocks there are actually of a complex volcanic nature, with significant faulting. Also, the industry was relying on an overlying layer of sedimentary strata to dilute and disperse any groundwater leakage, when the international criteria require such a layer to act instead as a barrier…The site is not suitable and investigations should be moved elsewhere…”.And: “The site selection process was flawed, not treating safety as the most importantfactor, and irrationally affected by a strong desire to locate close to Sellafield.” To repeat: The NIREX plan was for Deep Geological Disposal of LOW and INTERMEDIATE level nuclear wastes. The grandchild of NIREX is RWM and RWM’s plan is for LOW and INTERMEDIATE LEVEL wastes to be diverted to landfill, to "recycling" and to LLWR at Drigg. This frees up the GDF for the more Highly Radioactive HEAT GENERATING nuclear wastes that previously even NIREX thought too dangerous to be abandoned deep underground. Our own view is that nuclear waste should not be dispersed to the environment and abandoned. There is no operational GDF anywhere in the world for heat generating nuclear wastes precisely because problems of long term containment have not been resolved (and may never be within our timeframe). Until long term containment can be assured beyond all reasonable doubt then these wastes must be closely monitored and repackaged again and again and when problems arise they can more easily be remedied (The Chernobyl Sarcophagus was not fit for purpose after a decade). This would be an intergenerational endeavour. The current policy by RWM and now signed up to by the Borough Council is to leave future generations with no means of protecting themselves from a deep, leaking high level nuclear waste dump (under the Irish Sea?) and the "in tandem" leaking near surface low and intermediate level waste dump at Drigg. We urge Allerdale Borough Council to withdraw themselves from the so called “Community Partnership” at the earliest opportunity in order that the represented public can genuinely voice their own views on the governmental push for Near Surface and Geological Disposal/Dumping. Withdrawal from the Community Partnership would ensure that the local and wider public can voice opinion genuinely independent of the “Partnerships” influence which is filtered through the distorting lens of the predetermined interests of Radioactive Waste Management and the NDA. yours sincerely Marianne Birkby Lakes Against Nuclear Dump - a Radiation Free Lakeland campaign https://www.lakesagainstnucleardump.com/ References: Cumberland Including the Lake District https://www.alamy.com/stock-photo-antique-county-map-of-cumberlandcumbria-the-lake-district-john-heywood-176388087.html Turner: https://www.tate.org.uk/art/artworks/turner-the-harbour-at-parton-near-whitehaven-d12250 Lillyhall Landfill opened up to large volumes of man-made nuclear wastes https://www.copeland.gov.uk/sites/default/files/attachments/CIS/pdf/nwp_090409_item6.pdf Anger at Studsvik Decision by Local Businesses (now Cyclife/EDF) https://www.timesandstar.co.uk/news/17052632.anger-at-studsvik-decision/ Nuclear Laundry asks for Retrospective Planning https://mariannewildart.wordpress.com/2019/07/29/nuclear-laundry-asks-for-retrospective-planning/ Petition Against Radioactive Scrap Metal Overflow at Port of Workington https://www.newsandstar.co.uk/news/19442219.petition-radioactive-scrap-metal-plans-port-workington/ Letter to “The Guardian” of June 28,’07 by NIREX Inquiry Inspector Mr Chris McDonald https://www.theguardian.com/world/2007/jun/28/nuclear.uk The first indication of the NSD plan was hidden within an article in the "On the Level” Low Level Waste Repository magazine of March 21. The UKs Low Level (Nuclear) Waste Repository at Drigg is being eyed up for so called “Near Surface Disposal” of Intermediate Level Nuclear Wastes to be buried 10s of metres underground: "The Environment Agency has accepted the conclusions of an extensive LLWR review carried out to justify the safety of continuing to dispose of low level waste at the Repository until it produces its next Environmental Safety Case (ESC) in 2026. ….. LLWR had requested the rescheduling of the Safety Case due to a series of factors that caused delays in its ESC update programme, including its work on the NDA’s emerging Near Surface Disposal (NSD) programme. There are two main concepts being considered for NSD in the UK: at surface level and at depth, 10s of metres below the surface. Data from 400 points in and around the Repository has been collected to support feasibility studies to inform potential Near Surface Disposal (NSD) options in the future. The geophysics monitoring work to image the subsurface will help decide the best location for a potential NSD facility and inform the design optimisation process. NDA is exploring the benefits of developing NSD for disposing of a proportion of Intermediate Level Waste (ILW), but no decision has been taken on whether UK Government will pursue this option or whether LLWR, will in time, host a NSD facility. Optioneering studies are required to understand what’s possible on the site before any decision is taken on how to proceed. An NSD facility could bring benefits to the estate, for example by freeing up space in Sellafield’s Intermediate Level Waste stores, which could then be used for high hazard waste. The latest phase of the work sees the deployment of multiple wireless geophones along roadsides and the use of a specialist vehicle to generate vibrations into the ground," https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/994530/On_The_Level_Issue_27_March_2021.pdf, On the Level LLWR June 21 - page 8 of 8 "Ground has been broken on the third of 16 boreholes designed to provide additional data on the geology and hydrogeology of the Repository to inform NDA decisions over future options for the site. Boreholes will reach a depth of 120m into the underlying sandstone and the work is expected to continue until October. The LLWR study is part of wider exploratory work being conducted by NDA into near-surface disposal (NSD) options as a possible alternative for some of the less hazardous solid higher activity wastes currently intended for disposal in a Geological Disposal Facility. This type of waste could potentially be safely and permanently disposed of in near-surface facilities, comparable to those surface facilities already in place at the LLWR site, or at slightly increased depths, up to a few tens of metres. This type of waste is safely disposed in this way in other countries. LLWR’s study is expected to conclude in 2023, when it will be submitted to NDA for consideration. No decision has yet been made on whether to proceed with NSD and a decision to go ahead would require an update to current Government policy, which would be subject to a comprehensive consultation process. It would also be subject to the relevant planning, permitting and other licensing procsses – all of which include stakeholder engagement. https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/994531/On_The_Level_Issue_28_June_2021.pdf\ "All work is exploratory only at this stage, however if taken forward, a new NSD facility could be available within the next 10 years." https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/910184/NSD_StrategicPositionPaper_August_2020_FINAL_V2 ILW "In the corrosion and microbiological degradation of these substances, gaseous compounds are released. The corrosion produces hydrogen, while the microbiological processes transform the organic substances of the nuclear wastes into carbon dioxide or methane, depending on the redox conditions. ..The gases can have unfavorable effects during storage. For example, the increasing pressure can push the radioactive gases and solutions into the environment." https://www.sciencedirect.com/topics/chemistry/intermediate-level-radioactive-waste

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