photo by Tom Swinnen.
Radiation Free Lakeland – Nuclear Free Local Authorities joint media release, 27 June 2022. For immediate use ‘Lacking in scientific rigour’: Damning verdict of marine expert on Nuclear Waste Services seismic testing plan Radiation Free Lakeland (RFL) and the Nuclear Free LocalAuthorities (NFLA) have announced the publication of a report by a renowned marine expert which is highly critical of Nuclear Waste Services’ (NWS) proposal to carry out a seismic survey in the Irish Sea to further a plan for an offshore nuclear waste dump. The report, ‘The West of Copeland Acoustic Airgun Survey Proposal: A critical analysis Review Briefing’, was commissioned by Radiation Free Lakeland and supported wholly through financial contributions made by members of the public concerned about the harm that could be caused to marine life by seismic testing. The report was written by Tim Deere-Jones, a highly-regarded marine radioactivity and pollution researcher and consultant who has been working independently in this field since 1983. The NWS, an operating division of the Nuclear Decommissioning Authority, is responsible for finding a site for a so-called Geological Disposal Facility, either below ground or beneath the seabed. This nuclear waste dump will be filled with the toxic radioactive waste that is the legacy of Britain’s seven decades of the civil nuclear power production; much of it will remain radioactive for many tens of thousands of years. Three search areas in Cumbria, falling within the local authority areas of Allerdale and Copeland and offshore up to 22kms, are under consideration. Seismic testing will enable NWS to determine if the geology beneath the bed of the Irish Sea is suitable to host a repository for the nuclear waste. This involves firing blasts of sound from air guns below the waves every 10 seconds for four weeks or longer. This sound penetrates under the ocean floor to help scientists discover more about the suitability of the geology to store nuclear waste. Seismic testing can seriously impair the health of marine life, which in the Irish Sea includes whales, dolphins, porpoises, and seals, but some scientific reports also suggest that even tiny shellfish and plankton can be adversely impacted, hazarding the whole marine ecosystem. NWS have claimed an exemption from the requirement to seek a Marine Licence from the MMO citing their survey as furthering ‘scientific research’ and in so doing have prevented public analysis of their proposals or commentary from academics and marine welfare organisations. Mr Tim Deere-Jones’ report contests that the survey is in fact an activity that requires licensing as it is in furtherance of a commercial enterprise rather than to further the pursuit of science; that the documentation submitted by NWS to the MMO when seeking their exemption is selective when quoting from the existing body of scientific research and is ‘lacking in scientific rigour’; and that there are other unintrusive ways to conduct the survey that will leave marine life unharmed. A summary of some of the key points follows: NWS have adopted a very secretive approach. In citing an exemption, NWS has avoided public consultation, peer consultation (with academics, marine wildlife groups, government agencies across Irish Sea), and the public disclosure of documents. These documents were only revealed after FOI requests from Radiation Free Lakeland and the NFLA.
In claiming that the survey is being conducted for a ‘Scientific or Educational purpose’, NWS is misrepresenting the true purpose of the survey which it specifically to further a commercial proposal to construct a sub-seabed infrastructure, a nuclear waste dump, rather than for the disinterested pursuit of scientific knowledge.
NWS has issued contradictory statements about the area of testing. It remains unclear whether this is 250 km sq or 1000 km sq.
The Environmental Impact Assessment has been produced in-house rather than, as is more usual, commissioned from an independent source.
All the research conducted by NWS has been desk-top using third-party sources rather than first-hand on the ground field research.
The NWS has selectively quoted ‘SCANS’ survey data but failed to report that its authors had warned of specific ‘weaknesses’ for the testing area. The data for these areas was collated without the benefit of aerial reconnaissance and contains only estimates of the number of marine mammals to be found there.
NWS uses only two advisory studies of methodology for conducting environmental impacts and fails completely to take account of many other studies listing adverse impact of sound energy on marine life and ignores ‘important and precautionary warning from a leading fish scientist’ (Professor A N Popper).
The impact on testing on the Marine Conservation Zones (MCZ) which adjoin the testing area has not been identified as part of the NWS in-house assessment despite the clear evidence that marine life in these zones is well within auditory range of airgun blasting There is a failure to account for the impact of sound waves travelling into other areas of Irish Sea
There is still no research available on the impact of seismic testing on many species of marine life that can be found in the MCZ
Basking sharks, which are protected globally, are present in significant numbers in regional waters, yet the impact upon them of seismic testing has been virtually ignored in the NWS assessment.
The prolonged impact of seismic testing on fish stocks and the fishing economy in the Irish Sea has not been accounted for.
Even after the completion of a survey, the results yielded by the proposed testing method may remain ‘uncertain’ as these could be compromised by several probable regional factors (e.g. elevated suspended sediment concentrations; seasonal algae and zooplankton blooming; methane gas from coal fields; earthquakes; shallow sea depths; reverberation from air gun shots; and wave generated bubbles).
The NWS has improperly stated that ‘There is no suitable alternative non-intrusive survey method available to collect data on deep geology’, but the report identifies other testing methods which would be non-intrusive or harmful and yield better results
The report has been sent with a letter to the Chief Executive Officer of the Marine Management Organisation, Tom McCormack, by Radiation Free Lakeland, on behalf of both organisations, seeking a review of the survey proposal. In the letter, the MMO are asked to revoke the exemption and require the NWS to apply for a Marine Licence to enable full and proper consultation to take place with the public; elected members; environmental and conservation organisations; commercial marine users; and government agencies in the nations adjoining the Irish Sea and in the Isle of Man.
The two organisations also believe that the NWS should be obliged to commission a fully independent and comprehensive Environment Impact Assessment and that the MMO should urge them to adopt a non-intrusive survey method that will leave marine life unharmed. A response from the MMO is to date outstanding. Commenting, Marianne Birkby, founder and co-ordinator at Radiation Free Lakeland, said: “For Nuclear Waste Services to have sought to bypass the regulatory process in order to push ahead with hugely damaging seismic testing is a scandal! “The cost of the seismic blasting, £7.5 M would come from the public purse. The same public who have not had the opportunity to have a say on whether or not they want this damaging seismic blasting to go ahead. Personally, I have not heard anyone say that they are in favour of seismic blasting the Irish Sea to “investigate” the geology for a deep hot nuclear dump. “Tim Deere-Jones' report is a wake-up call and should set alarm bells ringing for elected representatives on the Community Partnership”. Councillor David Blackburn, Chair of the NFLA Steering Committee, added: “Mr Deere-Jones has done an excellent job in presenting a forensic analysis which highlights not only the great many deficiencies in the proposals submitted by Nuclear Waste Services to the Marine Management Organisation to survey the Irish Sea, but also the lack of current research into the impact of seismic testing on many marine species found in this body of water. “For the NWS, this report represents an opportunity to revisit its current plans. NWS could do the right thing in applying for a Marine Licence before proceeding and so demonstrate its commitment to be open and transparent to public and professional scrutiny. NWS could also choose to adopt a non-intrusive testing method, which would not only leave our precious marine life unharmed, but it could also yield better results. “Our challenge then to Nuclear Waste Services is will you do this?” The report’s author, Mr Tim Deere-Jones, concluded: “The Environmental Assessment produced by NWS has failed to research and comment on the likely impacts to so many regional marine species that it cannot provide a remotely adequate assessment of the impacts of acoustic surveying on the highly biodiverse marine life, designated marine conservation sites and commercially valuable species in the proposed survey area. “I recommend that survey is postponed until a fully independent Environmental Assessment has been carried out with the benefit of full public consultation engaging with regional residents, sea users and conservation bodies and an assessment of less intrusive survey methods has been investigated”. Ends://… Notes to Editors For more information about the work of the two organisations: Radiation Free Lakeland’s website can be found at: https://mariannewildart.wordpress.com/ The Nuclear Free Local Authorities website can be found at: https://www.nuclearpolicy.info/ More about the report author, Tim Deere-Jones, Marine Pollution Research & Consultancy: I’ve been working as an independent Marine Pollution Consultant/Campaigner and Researcher since the 1980’s. I was educated at the Cardiff University (Wales) Department of Maritime Studies, where my research dissertation and field work investigated the sea-to-land transfer of marine pollutants. Subsequently, I’ve worked on a wide range of marine, coastal and estuarine issues on campaigns covering marine environments from the Arctic to Australia and the Pacific. I have a particular interest, expertise and focus on issues related to marine radioactivity, marine hydrocarbon pollution and the environmental risks associated with the maritime transport of hazardous cargos. Working with citizens campaigns I have initiated, and helped carry through, a number of successful “citizens science” projects to gather independent, empirical evidence on specific marine pollution issues. My client base has included leading national and international marine environmental NGOs, Local Government organisations and Citizens Campaign groups. I have never worked for, or with the polluting industries or their sponsor governments. I am one of the very few marine campaigners to have had a formal face to face meeting with the Secretary General of the IMO. The purpose of that meeting was to discuss the risks associated with the maritime transport of radioactive cargo. My Fukushima specific printed and video Briefings on marine impacts have been translated into Japanese and widely disseminated in Japan. My contribution on marine issues, to the successful Greenlandic campaign to ban the mining of Uranium and Rare Earths has also been translated into Kalaallisut, the Greenlandic language.