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From Lakes Against Nuclear Dump to the Lake District National Park Authority. A letter of alarm regarding plans for an Intermediate Level Nuclear Waste Dump for the UK's Low Level Waste Repository at the village of Drigg. The UKs LLWR is 250 metres from the National Park Boundary at the nearest point. The following letter has been sent to local and national media and mainstream NGOs have been alerted.

Dear Member of the Lake District National Park Authority,

image from the Westmorland Gazette 1996 - Now the plan is to put the intermediate level nuclear wastes previously earmarked for the NIREX dump at Longlands Farm, Gosforth into Drigg and the even higher activity wastes into a GDF (under the Irish Sea?)

Congratulations on the 70th anniversary of the Lake District National Park. In the original Lake Counties is another 70th anniversary. The Windscale Piles. Which from 1951 produced plutonium for Britain to make its own atomic and hydrogen bombs until the Windscale Fire of 1957. Unfortunately lessons were not learnt. The nuclear experiment continues despite no final solution to the problem of what to do with the escalating wastes from 70 years of military and civil nuclear reactors. Our own view as a nuclear safety group is that the wastes should not be buried out of sight and out of mind but should be closely monitored and repackaged when necessary.

NIREX REBORN AT DRIGG? - Intermediate Level Nuclear Wastes for Burial approximately 250 metres from the National Park?

We have been alerted by locals in the Drigg area to a plan which is running in tandem with that for a deep Geological Disposal Facility which Government say: "will be available to receive the first waste in the 2040s” However the plan for Near Surface Disposal (10s of metres below ground) "could be available within the next 10 years.” This plan, for which the Low Level Radioactive Waste Repository at Drigg is under active consideration, is for the disposal/dumping of Intermediate Level Wastes of the type that were rejected by the NIREX inquiry for deep GDF disposal at Longlands Farm, Gosforth in 1997. Exploratory boreholes have already been drilled at Drigg for the Near Surface Disposal of Intermediate Level Nuclear Wastes, presumably under “permitted development.” Just like the early days of the Windscale Piles this plan has been put in motion under the radar of public attention. There has not been any debate or vote at Local, Borough or County Council level nor, we assume, any discussion by the Lake District National Park despite the Low Level Waste Repository being only 250 metres from the Lake District National Park boundary. Intermediate Level Nuclear Wastes, according to the Nuclear Decommissioning Authority, "exceeds the upper boundaries for Low Level Waste but does not generate a significant amount of heat. ..The major components of ILW are nuclear reactor components, graphite from reactor cores and sludges from the treatment of radioactive liquid effluents.”

The NIREX dump entrance proposal for Intermediate Level Wastes was rejected in the 1990s because the nuclear industry had no idea how much and how fast the planned dump would leak. They still have no idea. Furthermore for a shallow dump the leaks would be even faster.

A spokesperson for the Managing Radioactive Waste Safely process (which ended with Cumbria County Council’s refusal to continue “steps” in 2013) said at a public meeting in Cumbria on January 11th 2012 that ” the outcome of the NIREX Inquiry would have been favourable to geological disposal of high level nuclear wastes had all the information been available at that time”.

This claim by MRWS was quickly refuted by the Nirex inspector Mr Chris McDonald who wrote that he was concerned to hear : “…of your opinion that the outcome of the Inquiry would have been different…This was not a view put forward by Nirex … and it causes me some concern now. The fundamental conclusion of the expert Assessor and myself was that the Proposed Repository Zone had been chosen for these studies in an arbitrary manner, without conforming to internationally agreed, geological criteria.” He goes on to say. “It would not suffice in European Law to rely on the…voluntarism approach, since that attaches far too much weight to the transient views of the current population.”

Earlier in a letter to “The Guardian” of June 28,’07 the NIREX Inquiry Inspector 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 important

factor, and irrationally affected by a strong desire to locate close to Sellafield.”

The latest process to deliver a GDF (with Cumbria STILL in the frame), Radioactive Waste Management, is now in partnership with the LLWR at Drigg. These bodies along with the Nuclear Decommissioning Authority are all advised by the Committee on Radioactive Waste Management which is in turn taking “invaluable” advice on construction and delivery of deep (GDF) and not so deep (NSD) dumping/disposal from West Cumbria Mining's CEO Mark Kirkbride. Kirkbride compiled CoRWMs Annual Report No 3724 which details the push for Near Surface Disposal: "advice in the last year have 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 Lake District National Park Authority surely cannot ignore this. If Intermediate and heat generating High Level nuclear waste is brushed under the Lake District fringes and abandoned, then the World's Nuclear Heritage Site will soon become the World’s Nuclear Sacrifice Zone. This could happen within a decade for the Intermediate Level Wastes at Drigg. Please protect the Lake District and its fringes, tomorrow is too late to say “This Far and No Further."

yours sincerely

Marianne Birkby

Lakes Against Nuclear Dump - a Radiation Free Lakeland campaign


Coal Boss Mark Kirkbride compiled CoRWMs Annual Report No 3724 which details the push for Near Surface Disposal "advice in the last year have 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 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,"

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.

"All work is exploratory only at this stage, however if taken forward, a new NSD facility could be available within the next 10 years."

"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 formation of carbon dioxide is less important because the anaerobic conditions are dominant in underground disposal. The gases can have unfavorable effects during storage. For example, the increasing pressure can push the radioactive gases and solutions into the environment."

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