27/11/2014 Letter from Eddie Martin to NDA chairman Stephen Henwood

Chairman, The Cumbria Trust Ltd.
The Old School House
Cumbria, CA15 6SH

Stephen Henwood CBE
Chairman, Nuclear Decommissioning Authority
Herdus House (Head Office)
Westlakes Science & Technology Park
Moor Row
Cumbria, CA24 3HU

Dear Mr Henwood,

Thank you for your letter of 11th inst. and thank you also for your very prompt and comprehensive reply.

I found your letter interesting in that it gave some information as to what the NDA is doing concerning the Legacy Ponds, yet not as useful as, perhaps, it might have been. The reason for this is that although you give assurances over the NDA prioritising work on the Ponds, there was no clear outline of the plans for this work. I am aware of the detailed plans that the NDA has published; plans which no doubt will have finely-honed programmes on the exact actions to be taken attached to them. Yet there is, we feel, a distinct lack of connection between taking action – such as published plans on the NDA’s website – and the declared commitment of the NDA to engage with the public. For example, not many local people can make the stakeholder meetings you refer to; let alone others from across the UK who are also very interested in Sellafield’s operations.

In this situation the most people can hope for is to access the plans; which requires a good broadband connection and computer. A good printer is also essential as few could read or understand these documents on screen. Further, they would need a good idea of or background in the nuclear industry, if not an in-depth knowledge of some parts of it, to fully appreciate the plans.

We wish, therefore, to offer a suggestion that you might wish to act on: that the NDA produce specific briefs on the Legacy Ponds that were the focus of the recent press coverage. Such briefings need be no more than the key points on what will be done and when – outlining the basic actions that will be undertaken.

For example, a series of points on the spent fuel:

  • When it might be removed from the Ponds (which pond, etc)
  • What happens next – reprocessing? If so, briefly describe. Follow this with an explanation of  what happens to the products of reprocessing e.g. high level waste is vitrified etc; plutonium into storage etc.
  • Alternatively, what happens to that spent fuel which will not be reprocessed? How will that be conditioned for storage?
  • Does such conditioning e.g. encapsulation, leave it in the final form ready for disposal?
  • Similarly, what will happen to the liquors and sludge in the ponds; the solid intermediate level wastes and the contaminated water?

During the failed MRWS process, many of those who were pressing for the process to move to stage 4, chose to use the existing threat posed by high level waste (HLW) and spent fuel stored at Sellafield as justification for going to the next stage. Even the NDA’s Chief Geologist for Radioactive Waste Management, Professor Bruce Yardley, appointed earlier this year, has previously used this argument for proceeding to stage 4 in Cumbria. He did this while recognising that there are large areas of eastern England with far more suitable geology for a GDF.

This ignores a key and fundamental fact.

HLW and legacy spent fuel are not due to commence burial until 2075. Spent fuel from new build and plutonium if (when) it is reclassified as waste, can only commence burial in the 2130s according to the NDA. Why then has the NDA chosen not to correct this misunderstanding that the sooner we can build a GDF, the sooner this risk goes away? Is it because the purpose of this was to mislead people into believing that fast-tracking a Cumbrian GDF would reduce the risk to Cumbrians from these most dangerous substances, when in fact it does nothing of the sort? It is deeply regrettable that the NDA allowed this myth to continue to be used by those advocating a move to stage 4. Progressing with a GDF in relatively poor geology would ultimately expose Cumbrians and their neighbours to a great deal more long-term risk than necessary.

The inability to place these wastes in a GDF for such a long period, even if it were built tomorrow, yet again emphasises the urgent need to focus on long-term Secure Interim Storage at Sellafield. The argument around a GDF must not be allowed to distract from this primary requirement.

Which brings me to a second, perhaps an even more important point. We believe it would be useful for the NDA to indicate approximately when its actions will tip the ‘intolerable’ over to ‘tolerable’. At what date in the future does the balance of risk change beneficially from the current unfavourable position? Some idea of when the NDA’s actions will bear fruit, and the risk will be significantly reduced, would be both useful and encouraging for the public and for the members of Cumbria Trust. In this context, it is most encouraging to hear, for example, of the progress being made in completing the Sludge Packaging Plant and the imminent emptying of the FGMSP.

However, we note that the ONR has served an improvement notice on Sellafield Limited, requiring the company to improve the physical containment barriers and the resilience of the ventilation systems in the waste vitrification plant. We note also that there was a loss of power in November last year which resulted in radioactive contamination escaping from the shielded contained areas to the manned areas of the plant. Although no workers were exposed to radiation, staff had to be evacuated and the plant was shut down because of the widespread contamination. I believe that an expensive clean-up operation is still in progress.

We also note that the Final Report of HM Chief Inspector of Nuclear Installations, September 2011 stated:

“In some facilities that are no longer operational, but in which nuclear materials are stored prior to their complete decommissioning, it is neither reasonably practicable nor possible in some cases to close the gap with modern standards sufficiently, or possible to call an immediate halt to storage. The Sellafield legacy fuel storage ponds and intermediate level waste storage silos are the prime examples of such facilities. The physical structures and conditions within these decadesold facilities have degraded over the years and they now present risks which are of significant regulatory concern. “

 Additionally, others such as CORE, are impressively vigilant in highlighting apparent ‘failures’ at Sellafield, such as :

Whilst discovery on the beach at Sellafield of a radioactive stone in May bearing the highest level of Caesium 137 discovered since the current monitoring programme began is of great concern, the subsequent discovery in June of a radioactive particle on the more publicly accessible beach at Seascale requires urgent precautionary action to be taken by the Authorities to protect the general public.

This Seascale particle was found to have a radioactive contact dose rate of 2.8 milliSievert per hour (mSv/hr). Given that the Statutory Public Dose Limit for members of the public for a whole year is just 1 mSv (1mSv/yr), the particle clearly has the potential to pose a significant health risk to the public. Comprised of Caesium-137, Americium-241, Europium-154 & 155 and probably Strontium-90, the particle has been described by the Environment Agency (EA) as ‘being unusual as it was emitting mainly beta rather than gamma radiation’.”

CORE’s own comment suggests: ‘In light of this high dose rate of the Seascale particle, PHE’s time-wasting monitoring reassessment does nothing to protect beach-users here and now.

My colleagues and I – and, indeed, all Members of Cumbria Trust – fully recognise the enormous challenges which the NDA and Sellafield, in particular, face. However, the inherent and cumulative experiences and professional expertise of the staff are not only formidable, they are clearly world-class, as witnessed perhaps by the UK’s technical support for Fukushima.   We wish Sellafield to flourish; we earnestly wish for more nuclear-related employment and research here in Cumbria. But what are we to make of the multiple, conflicting advice and reports – official and otherwise – which circulate, particularly as regards the “intolerable risks…” and the apparent, inherent dangers? The NDA has not confronted those cumulative allegations or rebutted – line by line – the accusations which have been made by and from various, credible sources.

In light of the recent articles about Sellafield in national newspapers and given the plethora of anti-nuclear organisations and the continuing doubts many have about nuclear waste storage and disposal, how does Sellafield management intend to demonstrate to the British public that the nuclear industry is working effectively to acknowledge those many concerns raised and to demonstrate their immediate responsibilities to minimise the extreme risk that its Sellafield nuclear waste storage facilities apparently pose? At the moment, we would suggest, it is singularly failing to do so.

It remains difficult to obtain clear, comprehensive and unexpurgated accounts of the “intolerable” risks which we, here in Cumbria, apparently face and, what is of equal importance, the time-frame in which those risks will be significantly reduced. Much of the official material we read (including NDA’s own website and its published plans) is riddled with obfuscation and techno-gobbledegook. The periodic, ‘free’ insert which Sellafield/BEC distributes is redolent of and perfumed with self-congratulatory, self-adulating, ego-massaging messages – more like a motivational in-house staff magazine rather than an honest endeavour to communicate in unequivocal terms with the general public – particularly the general public of West Cumbria.

This is a most unsatisfactory situation. It behoves government-sponsored nuclear bodies (and the government) to tell the truth, the whole truth and nothing but the truth. Yet we find that a 16year old, 1998 report of the condition of the ponds at Sellafield continues to remain under a security classification. The possibility of importing additional, submarine nuclear waste and/or waste from proposed new nuclear reactors simply exacerbates our concerns given the chronic mistrust which many of us have in the nuclear sector and which has been fomented over many years.

We suggest that, collectively, we really must attempt to ameliorate and remodel the nuclear sectors interaction with those of us who are not nuclear physicists. We urge, yet again, for an opportunity to have a constructive dialogue and interrogation as we did so successfully a few months ago with the members of CoRWM.

Yours sincerely,

Eddie Martin

(for and behalf of the Cumbria Trust Ltd.)

(c.c. John Clark, NDA

Jon Phillips, NDA

Professor Williams, CoRWM

Baroness Verma, DECC

Rory Stewart, MP

Tim. Farron, MP

Lord Frank Judd, HoL.

Cumbria Trust Members

Stewart Young, Leader, Cumbria County Council)