A letter to the members of CoRWM (Committee on Radioactive Waste Management) from CT chairman Eddie Martin.

10th May 2014

Professor Laurence Williams, Chairman, and Colleagues
The Committee on Radioactive Waste Management
Room M09, 55 Whitehall
London. SW1A 2EY

VISIT OF CoRWM MEMBERS TO WORKINGTON, WEST CUMBRIA
30th April 2014

Dear Professor Williams and Fellow Members of CoRWM,

Thank you for visiting Workington, for hosting the public meeting, and for listening to the many concerns and comments which were raised at that meeting. You accepted that it would be useful if we would further explain and elaborate on our genuine concerns; that is what I now seek to do.

First, I must reassert that the Cumbria Trust (CT) (www.cumbriatrust.org) endeavours to be completely neutral on the proposed step-up in the installation and use of nuclear energy plants within the UK. The Trust has quite a catholic membership, with a wide spectrum of views, with Members from many walks of life and professions (including earth scientists), and of varying political persuasions. The CT welcomes that cosmopolitan and broad membership; however, some Members certainly do not support the further expansion of nuclear power in the UK, arguing that the building of nuclear power plants before an acceptable solution to the permanent disposal of nuclear waste is found is simply irrational. Others, whilst certainly not sanguine, accept that there is, indeed, a place for such nuclear power plants and recognise that Sellafield – for various and multiple reasons – might well be a location of choice. So, we attempt – successfully, I believe – to balance the conflicting views.

The Cumbria Trust has a number of objectives but prime amongst them are:

To campaign against any GDF in Cumbria on geological, environmental and safety grounds.
Campaign for safer, longer-term storage of nuclear waste currently at Sellafield and other UK nuclear licensed sites.

and it on these that I would wish to concentrate.

Whilst we appreciate that the international nuclear community has developed a consensus around the construction of geological disposal facilities (GDF) for nuclear waste that is unsuitable for near-surface disposal, with the other options ruled out, the logic governing the consensus is summarised by the UK’s Committee on Radioactive Waste Management (CoRWM), which explains the accord between the scientific and political communities regarding the preference for GDFs on the grounds that the risks associated with deep geological disposal are not as great as those presented by retaining HLW at surface level (CoRWM, 2006:195).

In other words, it became the consensus by the process of elimination, rather than by virtue of its outright advantages. However, we believe there is a general consensus amongst geologists that GDFs present the least worst option: those of us who have led vocal opposition to siting a GDF in Cumbria tend to agree that it is the location that is the problem, and not the concept (e.g. Carrington, 2013; Smythe,2011a).

That being the case, my colleagues and I were, nonetheless, concerned by the responses of some of your CoRWM Members who seemed to downplay the importance of the geological structure whilst apparently emphasising their confidence in engineered safety barriers – which is, in effect, an opaque safety case. We believe that CoRWM risks being judged complacent by taking the official SKB view of progress in Sweden, notwithstanding the fact that there is clear and compelling research evidence to suggest that copper canisters will, over time, corrode.

Dr. Ian Farnan, for example, from the Department of Earth Sciences, University of Cambridge, UK, states that scientists are still unsure of the best ways to store some long-lived radioactive elements, like plutonium and other actinides, that are created during nuclear fission. In truth, there is a range of chemical problems which have not and may not ever be solved.

You appear to imply in your Consultation Response at paras: 61-65 that the geology at Forsmark is of limited importance without mentioning that Forsmark was specifically chosen over an alternative site at Laxemar because there were far fewer fractures through which groundwater could flow. In other words it was, in fact, chosen primarily for its geology!

We know that any GDF must be sited in an area of relatively slow and predictable hydraulic gradients; a requirement that is categorically not met in West Cumbria where the topology pitches from the mountains to the sea (Smythe, 2011a). It is also extremely doubtful whether any site in Cumbria could meet the second requirement of geological stability, with its case being overstated and possibly fabricated in order to be considered for the first wave of site selection research during the 1980s (ibid: 1). The manner in which the geological suitability of apparently potential West Cumbrian sites has been misrepresented by those with an interest in ensuring its candidacy is deeply worrying and gives us considerable cause for concern.

The Nirex Inspector’s report, however, re-emphasises the two main points of consensus on siting guidelines:

“… the location should be in a region of low hydraulic gradients, so that there should be slow-moving and long groundwater pathways [and] the geology and hydrogeology of the site and its district should be readily characterisable and predictable.” Neither of those two requirements obtain in West Cumbria.

We understand that assessing any site requires four major areas for consideration: Thermal, Hydrogeological, Mechanical, and Chemical; in addition, geosphere change must be slow. We believe strongly that the over-reliance on ‘engineered safety solutions’ within a GDF (and as appeared to be advocated by CoRWM Members) is, therefore, flawed and potentially dangerous..

Yet CoRWM had previously stated: “…the geological barrier supports the engineered system and provides stability over the long term during which time radioactive decay reduces the levels of radioactivity. The geological barrier provides a stable environment over the long term and reduces the return to the biosphere of any radioactivity released from the engineered barriers.” (CoRWM, 2006: 116).

Here then, and somewhat paradoxically, the importance of the geological barrier is emphasised in addition to the engineered one: given the timescale within which nuclear burial operates, it is almost inevitable that the engineered barriers will be compromised and that radioactive material will be leeched into the surrounding geology. Yet as new technical solutions are developed so too is a sense of infallibility. An example of the failings of this reliance on engineered solutions comes from the recent history of the Swedish-developed KBS-3 buffer, which relies on storage of wastes inside of overlapping boron steel and copper alloy containers (Svensk Kärnbränslehantering AB, 2013). Until 2006 the KBS-3 method was the preferred engineered barrier of the BGS and Nirex yet, by 2008, problems with anaerobic corrosion of the copper component – an inherent structural flaw that would have substantially reduced its effectiveness as a barrier had it been employed – led to the BGS issuing a statement denying its suitability for the UK.

We fully understand that the two major encapsulation issues to be addressed are internal attack on the encapsulating material by the radioactive decay and external attack by repository groundwater. Current international research appears to highlight, however, how little we actually understand about the long-term behaviour of nuclear storage materials. “Clearly, efforts should be made to produce a waste form which is tougher and has a durability of which we are confident before it is stored underground and before anyone tries to engineer around it.” Dr. Farnan advises.

Further, Johan Swahn of the Swedish nuclear-repository watchdog, MKG, believes that new software which apparently enables the modelling of repositories and their contents to be undertaken, has little or nothing to contribute to research on radioactive waste disposal. He states that experiments carried out in URLs continue to throw up ” a lot of surprises”. He goes on: “…creating a generic safety case, with a nice visualisation, will in my opinion only enhance a dangerous belief in modelling, creating a false impression that we have understood more than we actually have”.

We remain unconvinced, therefore, that engineered solutions can be tailored to fit the geology.

With so much scientific uncertainty and, indeed, scientific conflict of opinion there are clearly multiple assurances yet to be made and many caveats yet to be heeded before the public can be entirely confident that a GDF, anywhere in the UK, is the optimum solution to the permanent disposal of HLW. We hope that CoRWM will be rigorously addressing those caveats and seeking those reassurances in due course and advising the government (and the general public) accordingly.

Our second area of concern is the seeming predilection of DECC, NDA, government ministers and others to return to Cumbria, time after time.

Despite the decision of Cumbria County Council on 30th January 2013 to reject further progression to Stage 4; despite the absence of three green lights which Ministers had proposed must be present before further progress could be made; despite the inherent flaws in the MRWS process and the extremely dubious market research/opinion polls undertaken; and despite the overwhelming evidence (geological, NIREX conclusions, planning inspectors, and other) against siting a GDF in West Cumbria we have never received a categorical assurance that the search for a GDF location in West Cumbria is over.

We cannot understand how DECC, NDA, CoRWM and others cannot or will not accept apparently the geological and plethora of other evidence that West Cumbria has, over time, been thoroughly and exhaustively explored and that it is too fractured, faulty and fissured to be able to accept a GDF anywhere within its boundaries.

I enclose two maps which clearly show the extent of known exploratory bore holes made in West Cumbria in the search for coal, gas, oil and water aquifers.

Borehole Map 1 photo 1

In addition the comprehensive work of Professors Smythe and Hazeldine has added considerably to our knowledge of the geology, and particularly the hydrogeology, of West Cumbria, which was complemented by the excellent data elicited from the 29 Nirex boreholes. It is surely disingenuous to suggest that not enough is known about West Cumbria’s geology.

It is simply irrefutable that the geology of West Cumbria – whether the Mercian mudflats of the Solway Plain or the granite composition of Ennerdale – is quite unsuitable for a GDF. No amount of protest, explanation or posturing by the NDA or others will convince us that they appear willing to accept this fundamental and basic premise. Hence, we draw the conclusion that NDA et al are obsessed with siting a GDF in West Cumbria for socio-political and economic reasons and convenience rather than for sound scientific and geological motives, the primary concern of which must be for optimum safety.

We have persistently and consistently argued for a national geological survey to identify potential sites in England (and Wales) as, indeed, did the vast majority of responders to DECC’s recent consultation exercise, but DECC appears to have conveniently parked our arguments in a cul de sac. We know that other regions are more geologically suited (such as in East England: Norfolk, Suffolk, East Midlands), yet we do not see the NDA (or CoRWM) visiting these areas or extolling the virtues of constructing a GDF in those regions. If other regions of England are more geologically suitable why are such regions not being enticed and considered?

In addition to the geological boreholes in West Cumbria, there are multiple National Coal Board maps which clearly show the extent of faults and fractures in much of the West Cumbrian geology. In essence, we believe that there is overwhelming evidence to illustrate clearly that the area remains completely unsuitable for the construction of a GDF. It is facile, if not fatuous, to suggest that not enough is known about the West Cumbrian geology.

What is perhaps relevant here, I believe, is the underlying conflict that has been established between the geological argument against the area and the emphasis on voluntarism that ultimately led to West Cumbria being the only region under serious consideration (and, we believe, continues to be so…). What is also highly relevant (and I am sure you will have picked this up at the public meeting) is the fundamental and deep-rooted lack of trust which currently obtains between the government’s assorted nuclear departments and the multiple and varied organisations such as the Cumbria Trust, other NGOs and the local authorities. What is driving this mistrust is not completely understood, although many believe that the socioeconomic and political considerations are being given priority over the more germane scientific and geological considerations. If true, that is surely perverse.

To ensure that (the new/reinvigorated) CoRWM-3 does not inherit a similar mantle of distrust we believe that CoRWM must unequivocally assert its independence by challenging the government’s conclusions (and especially the pontifications and proselytizing of the NDA, DECC, et al) but which, thus far, we have seen little evidence of; such influence on Ministers as CoRWM can bring to bear needs to be evidenced, CoRWM’s comments and conclusions need to be delivered in plain English, and their communications need to be utterly transparent.

My third point concerns the Right of Withdrawal. As Leader of the County Council during MRWS, I tried repeatedly to persuade Ministers to enshrine in appropriate legislation the right of a community to withdraw from the GDF process. We remain hopeful that perhaps such legislation might be included in the forthcoming White Paper. This apparent or, at least, perceived lack of willingness or commitment by Ministers proved to be one of several stumbling blocks which persuaded the County Council to withdraw.

At the public meeting CoRWM Members appeared to argue that the Right of Withdrawal could be exercised at any time but failed to clarify by whom and by what process. This is a fundamental point as you appear to be arguing that there should be one test of public opinion and that this should take place as near as possible to the point where the implementing organisation (the RWMD) is in position to deliver a DCO. Up to that point, however, the RWMD appears to be free to undertake whatever investigative work it chooses. Time and resources will have been committed; money will have been expended. It is perhaps unrealistic to expect DECC to allow the process to be abruptly terminated without further manipulation of public opinion,
which is why it is not hard to imagine that it might decide to depart from the principle of voluntarism or attempt to continue the process under the pretext of ‘the national interest’.

Your document (3138) does not clearly state that the public should have the right of withdrawal throughout the ‘continuum of engagement’; instead it simply mentions the removal of hard decision points. As the document currently stands the continuous RoW could be assumed to rest with the Representative Authority and we have no doubt that DECC would choose to interpret the document in this way. Your statements, therefore, lead to some considerable ambiguity. If the public will have a continuous Right of Withdrawal that needs to be clearly stated.

In addition, your Consultation response (paragraph 67) makes it clear that a DCO is required before seismic is shot and boreholes are drilled. Yet your paragraph 14 states that the Right of Withdrawal goes before a DCO is made. If there is a single DCO in this process it means that the RoW would disappear very early in the process, and well before any safety case could be made.

My fourth point concerns the establishment of the ‘Representative Authority’. Neither the government nor CoRWM (or any other government body/department) has satisfactorily defined ‘the community’; still less the ‘community’ which is likely to be affected by the construction and operation of a GDF. Clearly, ‘the community’ will be significantly wider than that juxtapositioned to a GDF facility. Communities many miles from the site will inevitably be affected by construction and radioactive waste traffic for many, many years, farms, businesses, private dwellings, hotels and tourism will inevitably suffer from ‘planning blight’. Capital values will depreciate.

Understandably, there will be huge opposition from the local populace which cannot be dismissed or shrugged aside as Lord Neill of Clackmannan attempted to do so in a recent debate by Members of the HoL S&T Committee during which he said;” I realise that under the old system that a decision was going to be made but it seems that the interests of bed and breakfast providers in other parts of England were of greater significance than finding a bed for nuclear waste.”

Inevitably, Lord Neill’s remarks did not go unnoticed. A profoundly irritated Chairman of the Cumbria Tourism Association, Eric Robson, wrote to Lord Neill:

“May I point out that the bed and breakfast providers you so sarcastically dismiss in your statement are part of a vibrant industry that produces £2.1billion each year for the Cumbrian economy and supports over 55,000 jobs in the county.”

Most parts and many people of Cumbria, as well as many industries/businesses, will be affected by the imposition of a GDF, and Cumbria simply cannot afford to lose any businesses or any jobs. Far from creating jobs, as is frequently postulated, the imposition of a GDF will, many believe exacerbate unemployment. A responsive County Council simply cannot allow that to happen without some kind of compensating/corrective mechanism such as the introduction of a Sterling Wealth Fund which, again, we have consistently argued for, but to little avail.

As the Nirex planning Inspector observed:

“It would be an economic detriment to significantly consolidate the nuclear industry by establishing the repository near Sellafield. There could be noteworthy effects on tourism, fisheries and inward investment in business”

and :

“… There are strong indications that there may be a choice of sites in different parts of the earth’s crust in the UK with greater potential to meet legal and regulatory requirements…”

Yet, CoRWM finds it “understandable” that a District Council – the size of Copeland – could be invested as the Representative Authority. Finding it “understandable” is surely giving tacit agreement – if not approval; such a phrase is, as a minimum, misleading if not ambiguous. One can only speculate whether central government and its many departments actually understand the role and remit of local government. Given the very limited remit of a District Council, its dearth of resources and its small sphere of statutory influence frankly it is not “understandable”. To give a small District Council, such as Copeland, the same responsibilities and authority as a multi-function unitary authority, such as Northumberland which is eighteen times the size of Copeland, yet to deny such responsibilities to Cumbria County Council (or any County Council) which has considerable statutory obligations, including waste disposal, transport and highways, and Fire and Rescue Services (and Emergency Evacuation Zones) is perplexing if not bizarre…

Inevitably, there are many who are deeply suspicious of DECC’s motives in proposing this fatuous and certainly manipulative arrangement… and we witness, yet again, the element of trust being further eroded.

Given their multiple responsibilities, including strategic planning obligations, county councils equate much more with unitary authorities than do District or Borough Councils and must, therefore, be included as fully participative decision makers; as the Representative Authority. Indeed, there are many in Cumbria who believe the county must, in due course, become a unitary authority in its own right and would, therefore, assume the mantle of ‘Representative Authority’ because Copeland would be no more. In addition, the inclusion of a county council enfranchises all voting residents of that county which, in effect, is the community and which, in turn, should be entitled to vote in the event of a ‘community referendum’.

The recent leak at WIPP, Carlsbad, has seen plutonium and americium detected some 40+ miles away due east of the facility; pollution being carried by the prevailing wind at the time. An investigative report has now been published which suggests that safety was compromised. Prevailing westerly winds from the Gulf Stream indicates that the rest of Cumbria MUST have a say in any proposed siting process should it return to Cumbria. Indeed, of itself, the WIPP leak should give CoWRM a clear understanding as to why only large representative areas at county level (and responsible for implementing the Emergency Evacuation Zone) should be considered as the Representative Authority.

It would be remiss of me not to mention that many colleagues believe that a local GDF decision making body must be truly representative of all community interests and should include all tiers of local government and relevant NGOs. That’s democracy!

May I highlight another peculiarity which would be reduced if government departments, or, at least, the Ministers and civil servants involved, would talk occasionally to each other; I believe the current phrase I am searching for is is ‘joined-up-government’.

In 1997, the then Department of the Environment turned down the Nirex application for a RCF at Longlands, near Sellafield, because of – among other reasons – its proximity to and the adverse impact on the Lake District National Park (LDNP). Given that decision, one might be hard-pressed to understand why any site neighbouring the National Park might be still being considered as a possible GDF location. It is worth noting that the LDNP has now made a bid for World Heritage Status with the support of the Department of Culture, Media and Sport (DCMS).

Here then we have a situation in which DEFRA’s forerunner, the Department of the Environment, has already made clear the government’s views on siting a GDF in West Cumbria on the edge of the LDNP. DCMS is supporting the bid for World Heritage Status; yet, it would appear that DECC is still attempting to site a GDF either on the edge of or within the LDNP. We would be grateful if CoRWM could point out to Government that there appears to a conflict between no fewer than three government departments, and that perhaps such departments should be speaking to each other.

We must emphasise that an environmental bottom-line must be clearly established; namely that intrusive borehole investigations and any potential surface structure – let alone a GDF – cannot be permitted within or allow to adversely affect nationally and internationally protected areas such as National Parks, AONBs, World Heritage sites or Natura 2000 sites.

In February 2013, the Deputy Leader (a Labour Member) of the County Council and I (a Conservative Member) as Leader wrote to the Secretary of State:

“We are acutely conscious of West Cumbria’s dependence on the nuclear industry which, with the associated supply chain, directly or indirectly provides some 30,000 jobs. (As a county council …) We would, indeed, wish to see West Cumbria become a world-renowned centre of nuclear excellence. And we see no contradiction between this ambition and our decision last Wednesday.”

Members of the Cumbria Trust are not Luddites. We appreciate that we have lived with Sellafield for more than 70 years (although I do STRONGLY recommend that Members of CoRWM acquaint themselves with Jean McSorley’s comprehensive study ” Living in the Shadow”; ISBN 0-330-31331-2 which may indicate why many people in Cumbria have strong, nuclear reservations) and that 70+% of the UK’s nuclear waste is stored at Sellafield. It follows then that we would welcome greater investment and advanced technology as well as and better and safer security and storage facilities at Sellafield. Not to mention greater investment in nuclear research. We do, indeed, wish Sellafield to become an acknowledged world leader in nuclear excellence.

It was immensely disappointing, therefore, to read the indictments and criticisms made by the Public Accounts Committee and the National Audit Office.

“An ‘intolerable risk’ is being posed by hazardous waste stored in run-down buildings at Sellafield nuclear plant, a watchdog has found. The National Audit Office (NAO) also said that for 50 years, the operators of the Cumbria installation failed to develop a long-term plan for waste. Costs of plant-decommissioning have also spiralled out of control, it said.” (BBC News. 7th Nov. 2012)

and

“Hazardous radioactive waste is housed in buildings which pose ‘intolerable risks to people and the environment’. My concern is that unless the authority holds Sellafield Ltd to a clear and rigorously benchmarked plan, timetables will continue to slip and costs spiral.” (Margaret Hodge, Chairman of the Public Accounts Committee).
Given that the role of CoRWM is “to scrutinise and advise on Government and NDA preparations and plans for the implementation of safe interim storage and subsequent deep geological disposal of higher activity radioactive waste ” (Professor Robert Pickard. 1st June 2011), what measures are CoRWM recommending to Government and NDA to reduce the ‘intolerable risk’ which Cumbrians and others are being exposed to? On a scale of, say, 1 – 10, how ‘intolerable’ is the risk to which we are being exposed or likely to be exposed? And how will we know, and who will tell us, when that ‘intolerable risk’ becomes more ‘tolerable’? In fact, without issuing every resident of Cumbria with a dosimeter how do we know what the tolerable rad or Gy or Sv is? And how often will it be measured?
Mrs Hodge’s remarks may be judged a little intemperate perhaps; nonetheless, when a senior politician of her standing and experience utters such phrases we should all take notice. We want there to be a minimal risk posed by Sellafield.
My county council colleagues and I pleaded frequently for greater and more focused investment at Sellafield to ensure safer storage. There is much construction work currently taking place (as you will have seen), but the general public is not informed of progress in reducing that ‘intolerable risk’. What bench marks are in place and within what time-scale? We are not informed. There MUST be greater, plain-English communication between Sellafield and the Cumbrian population. My colleagues and I at the County Council repeatedly urged the Government and DECC to adopt a ‘twin-track’ approach to nuclear waste: safer and more secure storage at Sellafield whilst searching elsewhere in England for a GDF location. Little came of our entreaties.
We are advised that Sellafield is the 6th most radioactive site in the world (some argue it is the 3rd), yet Cumbria as a community, and West Cumbria in particular, benefits only marginally and receives little compensation for living cheek-by-jowl with such an intolerable risk. We believe that this is simply not acceptable. We do not ‘blame’ Sellafield; we do ‘blame’ successive governments, however, for failing to appreciate the ‘intolerable risk’ and to compensate the community adequately.
I had intended this to be a short letter! My apologies. The storage and disposal of nuclear waste is a subject which preoccupies Cumbria Trust Members, and many others, very greatly. I would be pleased to answer any questions and welcome any opportunity to explain further.

Yours sincerely,

Eddie Martin, OSt.J., MSc, DMS (Dist.)

Chairman

Cumbria Trust.

 

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