Sellafield’s massive water abstraction plan for its new construction work has no environmental impact assessment and inadequate monitoring
- wastwater1
- May 7
- 7 min read
Sellafield blithely apply to the Environment Agency for new water abstraction and in the same application admit that they have already contaminated the freshwater aquifer beneath them
Lakes against Nuclear Dump and Nuclear Free Local Authorities joint media release, 6 May 2025. For immediate use.
Campaigners concerned that Sellafield’s water abstraction plan has no environmental impact assessment and inadequate monitoring
In a recent response to an Environment Agency consultation on a application by Sellafield Limited to extract water to support construction work at the site, campaigners at Lakes against the Nuclear Dump [LAND], a campaign of Radiation Free Lakeland, and the UK/Ireland Nuclear Free Local Authorities have expressed concerns that no environmental impact assessment has been carried out and that plans to monitor contamination in discharges are inadequate.
Sellafield plans to extract an additional 350,000 cubic metres of water a year from the Lake District to support the construction of new facility to repackage radioactive waste, whilst proposing to discharge almost a million litres of contaminated water every day into the River Calder and out into the sea. This for an indefinite and uncertain period.
LAND and the NFLAs are concerned that this will be done without an Environmental Impact Assessment being carried out and with no proper plans in place to monitor the discharged water, adding to fears that the work will lead to yet more radioactive contamination in the already fragile local environment.
Sellafield may believe that the discharges are safe and within legal limits, but the two campaign groups do not subscribe to the view that there is a safe limit when it comes to radiation and in recent years there have been large research studies demonstrating the cumulative effects of low-level, but legal, radiation on human health.
Ends//..For more information please email Richard Outram, NFLA Secretary at
This media release can be found on the NFLA website at:
https://www.nuclearpolicy.info/news/campaigners-concerned-that-sellafields-water-abstraction-plan- has-no-environmental-impact-assessment-and-inadequate-monitoring/
“No-one begrudges the nuclear industry repackaging the wastes - we are relying on them to repackage the wastes again and again into eternity, but we should absolutely begrudge them the label of ‘clean energy’.
“An industry that produces wastes that should be isolated from the biosphere and has permanently polluted an existing major aquifer as they admit in this water abstraction application is not “clean.”
The joint submission reads:
To the Environment Agency Wednesday 23 April 2025
By email to PSC-WaterResources@environment-agency.gov.uk
Comments on the Consultation on the Box Encapsulation Plant Product Store 2 Abstraction Licence Application at Sellafield Limited - Ref NPS/WR/042908
We are submitting this joint response on behalf of
Lakes Against Nuclear Dump (LAND) a body of local independent volunteers working to stop nuclear waste dumping in Cumbria and beyond.
The Nuclear Free Local Authorities which is a network of affiliated local authorities and elected members opposed to nuclear power
This application is for “a full licence to abstract water from the Alluvium Sandstone Deposit at Sellafield, Cumbria, within the area marked by National Grid References NY 03193 03004, NY 03240 02991, NY 03175 02939 and NY 03223 02927.
The application is to abstract water as follows:
40 cubic metres an hour
960 cubic metres a day
350,400 cubic metres a year
between 1 April and 31 March inclusive in each year.
The water will be used for the purpose of dewatering to aid construction.
‘The Box Encapsulation Plant Product Store 2 (BEPPS2) facility is one in a series of Intermediate Level Waste (ILW) stores required to provide future storage and enable operational continuity for High Hazard Risk Reduction work at Sellafield. BEPPS2 construction excavations will generate construction waters – rainfall, infiltration through soil, and groundwater due to digging and piling required for construction. This will initially require an Abstraction Licence to dewater excavations and transfer the collected water for discharge.’”
Obtuse Documentation for Tunnel Excavation and 17 Piles
The documentation is somewhat obtuse, but our understanding is that the applicant intends to dig a tunnel and drive multiple piles into the alluvium sandstone below Sellafield to support the construction of the BEPPS2.
Whilst we support the repackaging and transfer of Magnox wastes into bespoke packaging and into a bespoke facility from the wholly-inadequate silos from which such wastes have been leaking continually into the groundwater for decades, we are concerned that the proposal will involve nearly 1 Million Litres of Contaminated Water being discharged into the River Calder and out into the sea Every Day For An Unknown Length of Time.
This without any Environment Impact Assessment having been undertaken nor any proposal for efficient and adequate discharge monitoring being identified by the applicant.
In the letter from Sellafield to the Environment Agency (EA), ref WR188, dated 23 September 2024, Sellafield failed to provide correct grid references for the abstraction nor was a map provided. Based on the National Grid references made by the EA we have determined the locations to be as follows:
Method and Amount of Water Abstraction
The EA appears unsure about the method of water abstraction - whether from boreholes or sump - with Sellafield’s obtuse reply being that the water would be generated by ingress from new tunnel excavations (where are the diagrams/explanation for this tunnel?) and 17 piles presumably to facilitate the foundations and infrastructure for the BEPPS2
The 17 piles and the tunnel would produce what Sellafield considers ‘to be a very low volume of water (1237.5m3 (487.5m3 + 750m3)) for a planned short duration of time’.
This is 1,237500 litres - and is at odds with the amounts and time stated in the EM-2024-049 Supporting information:
‘June 2024 – November 2031.
Maximum volume to be extracted each year - 350,400 m3 (based on full daily allowance every day for a year).
Maximum daily amount - 960 m3/day (based on daily allowance).
Maximum hourly amount - 40 m3/hour (based on a 24-hour shift).
Number of hours per day water is abstracted - 24 hours continuous for construction of drains tank. Maximum flow rate - 11.1 l/s (based on daily allowance)’
Calder Interceptor Sewer
In the letter from Sellafield to the EA dated 23 September 2024 it states that water discharges would be made to the Calder Interceptor Sewer.
Although the EA asks for site diagrams, Sellafield has in its reply ignored this request and simply states that ‘The Calder Interceptor Sewer (CIS) receives donor feeds from process plants, landfill leachate and surface water drainage from the east side of the River Calder. Donor feeds must comply with the condition for acceptance shown in Table 5.’
It stretches credibility to hear that the Environment Agency, who are tasked with monitoring of Sellafield discharge (or at least providing third-party oversight) would need to ask for a site diagram of the Calder Interceptor Sewer, rather than already having it, but we are also concerned that Sellafield simply has not complied with your request.
In any event Sellafield in their ‘EM-2024-049 Supporting information’ state that ‘any discharge point within the CIS catchment may be used by the project’. We assume that these discharge points will not be monitored at all as is the case with the application for Outfall X discharge into the River Calder. In the Sellafield application to the Environment Agency dated 30th June 2023 it stated: ‘It is (Sellafield’ s ) intention, considering that any radioactivity present will be below typical limits of detection (LOD), that Outfall X will be managed through existing management system arrangements.. and will not be subject to any monitoring or discharge reporting against Site limits.’
https://www.nuclearpolicy.info/wp/wp-content/uploads/2023/08/Joint-submission-re-EPR-KP3690SX- V013-RSA-Environmental-Permit-Variation-Consultation-Sellafield.pdf
Monitoring
The application assumes that any discharge point, as well as the Calder Interceptor Sewer, will be used.
We note that Sellafield’s Discharges and Environmental Monitoring Report published in 2022 states:
‘Calder Inceptor Sewer Analytical measurements, limits of detection and rounding of data. All measurements of radioactive discharges, concentrations of radionuclides in the environment and radiation dose rates are subject, as with any other type of measurement, to uncertainties arising from the measurement process itself. These may become important when the quantities involved are very small compared with the measurement uncertainty, and the result is then quoted as a ‘limit of detection’ (LOD) (i.e. with a ‘<’ sign). This value is chosen to give a high degree of confidence that the actual result is less than that value.’
https://www.gov.uk/government/publications/discharges-and-environmental-monitoring-annual- report-2021/discharges-and-environmental-monitoring-annual-report-2021
Apart from the ‘rounding of data’ and ‘uncertainties arising from the measurement process’ the application does not give any indication of what the limit of detection is to be set at (and is of no consequence to ‘any discharge point within the CS catchment.’)
Impact on groundwater
Sellafield admit to the industry’s ‘permanent degradation of water quality’ of the secondary and principal aquifer from their existing works:
‘Groundwater – Moderate
This reflects the presence of a secondary aquifer and a principal aquifer which is downgraded by long- term / permanent degradation of water quality by the wider Sellafield works and is not abstracted locally.’
Pile driving is known to adversely impact groundwater especially such deep pile driving into alluvium sandstone holding an aquifer.
The West Cumbria Aquifer is a vitally important freshwater resource in an increasingly water stressed environment and to so blithely admit to its degradation with an application to further add to that blight is shocking.
Geological Stability
Theproposalistodrive17pilesintothealluviumsandstone. TherehasbeennoEnvironmentalImpact Assessment that we can see despite the unique vulnerabilities of the already contaminated site with already complex boreholes and existent piles along with the complexities of driving piles into sandstone:
The Sellafield site itself is vulnerable to liquefaction made more likely by impacts on groundwater such as massive ongoing abstractions from invasive works.
We would also like to restate that we do not subscribe to the view that there is a safe limit to exposure to radioactivity.
In May 2018, the US National Council on Radiation Protection and Measurements (NCRP) published ‘Commentary No.27, Implications of Recent Epidemiologic Studies for the Linear-No Threshold (LNT) Model and Radiation Protection’.
The NCRP concluded that ‘the recent epidemiologic studies support the continued use of the LNT model for radiation protection. This is in accord with judgements by other national and international scientific committees, based on somewhat older data, that no alternative dose-response relationship appears more pragmatic or prudent for radiation protection purposes than the LNT model.’
The model says that the relationship between cancer risk and radiation dose is linear, so even at low doses there is still a small cancer risk.
In the recent DESNZ consultation on the Management of Radioactive Substances, Para 1.5 detailed some key considerations upon which policies on the management of radioactive substances and nuclear decommissioning are based. These included: protection of human health and the environment; minimising the impact on the environment; and minimisation of greenhouse gas emissions. Part 2 also declares that (in para 10.10) ‘the protection of human health and the environment requires that, so far as is possible, radioactivity should not be introduced unnecessarily to the environment and any risks from radioactivity are kept as low as reasonably achievable.’
It therefore follows that it is unethical and immoral to knowingly increase releases of radioactivity into the environment no matter how small when this can be avoided.
Thank you for considering our comments. We await the conclusion of the consultation and the EA’s decision with interest.
Please in the first instance send an acknowledgement of receipt of our submission by email to NFLA Secretary Richard Outram at richard.outram@manchester.gov.uk and any further updates to this same email address.
Yours faithfully,
Marianne Birkby,
Lakes Against Nuclear Dump
Richard Outram,
UK/Ireland Nuclear Free Local Authorities
Comments