Background
Cumbria Trust welcomed the 2014 decision to conduct a national geological screening exercise – something which we had been pressing for since our formation a year earlier. At the time it was one of the few positive signs in the 2014 White Paper that the Dept for Energy and Climate Change (DECC) had learned lessons from the failure of the Managing Radioactive Waste Safely (MRWS) process and was beginning to listen to opinions other than its own. MRWS had illustrated the need for a new approach, since the only area to volunteer was West Cumbria (Allerdale and Copeland), despite the area previously been investigated at great expense and ruled unsuitable.
MRWS conducted a geological screening exercise, limited to West Cumbria, as stage 2 of the process. Unfortunately the way this screening exercise was conducted was an example of the dishonesty and lack of transparency which blighted much of the MRWS process.
A draft screening report was finalised in July 2010 by the British Geological Survey (BGS). However, it reached a conclusion which was a long way from DECC’s desired outcome, in that it effectively ruled out those parts of the borough of Allerdale which were outside of the National Park. The logical consequence of this, assuming that Allerdale wouldn’t support a Geological Disposal Facility (GDF) within the Lake District, would be for Allerdale to withdraw from the process, leaving only Copeland. Rather than accept and publish this report as planned, a decision was taken behind closed doors to ask the BGS to amend the screening report to produce a version which suited DECC’s plan. This was politics taking precedence over science. Three months later, in October 2010, a new version of the screening report was published, and this time an area of northern Allerdale close to Silloth, large enough for a GDF, was no longer excluded. The draft version was suppressed and all requests to see the draft report were refused. Fortunately, someone within the BGS decided that they could not go along with this behaviour, and leaked the draft report, which is how we discovered the scale of the manipulation which had taken place.
Against that troubling background, while Cumbria Trust welcomed the 2014 decision to produce a national geological screening report, this was not without significant reservations. Our concerns increased when we discovered that unlike in 2010, the BGS were not going to be allowed to produce this new report on their own. The BGS would be asked to provide the mapping, while the narrative would come from Radioactive Waste Management (RWM), the developer of the GDF project. We felt that there was a clear conflict of interest here – as developer, RWM have a strong incentive to talk-up the geological suitability of different areas, to encourage volunteers. In order for the screening report to be useful, it had to be considered trustworthy and impartial. RWM’s involvement puts that into doubt as we have made clear to RWM on a number of occasions.
Cumbria Trust also raised this conflict of interest with the Independent Review Panel (IRP) whose remit was to ensure that the process was technically robust. Two members in particular supported our view that RWM’s role in providing the narrative may be inadvisable due to this conflict of interest, and that it could leave open the possibility of perceived or actual manipulation. Unfortunately, despite this support, RWM refused to alter its position and was determined to press ahead with providing the narrative itself. We feel that it would be valuable to have IRP’s assessment of the final reports
Dilution/removal of exclusion criteria
We note that during MRWS, the presence of certain minerals (coal, oil, gas, and some metal ores) were considered to pose sufficient risk that a future society may inadvertently damage a GDF in the process of exploration, that these areas were excluded from the GDF siting process. Similarly the presence of aquifers, and shallow permeable formations, were also exclusion criteria.
The new screening report removes these exclusions and therefore increases the risk of future intrusion. It is notable that where RWM is aware of a current resource licence, they say that they will monitor how the exploration process proceeds to see if it is commercially viable. This implies that if these are found to be non-commercial, they won’t automatically be excluded from a GDF siting process. In the view of Cumbria Trust, this is a very short-sighted approach and poses a significant risk to the long-term integrity of a GDF. One key factor in assessing commercial viability is commodity price. The higher the price, the more likely it is that extraction can be carried out commercially, so to base an assessment of future intrusion risk on commercial viability at today’s commodity price is not sensible. We can’t reliably predict commodity prices a year from now, so we have absolutely no way of knowing where they will be over the lifespan of a GDF.
Relative geological suitability
While we accept that it is a complex matter to assess the relative suitability of different regions for a GDF, the geological screening reports appear to make no attempt at all to compare regions. One of the clearest lessons from the Nirex process was that complex geology makes it difficult or sometimes impossible to model groundwater flow, even over modest distances. After spending hundreds of millions of pounds, Nirex’s Director of Science, John Holmes, concluded that they needed between ten and a hundred times more data to have any chance of producing an adequate model of the flow between two boreholes, just 200m apart.
This was one of the factors which led Chris McDonald, the Lead Inspector of the Nirex Inquiry, to advise that the search should move away from Cumbria to an area of simpler geology. And yet in producing this screening report, these expensive lessons from past failures have been ignored. While major faults are mapped, and acknowledged, the significance of simple geology in site characterisation is not well communicated.
Geological accuracy
Having examined the reports which cover Cumbria, we are concerned that a cross-section shown below (Northern England Regional Geology, page 11) which cuts through Cumbria may not correctly represent the Lake District Batholith, shown in red on the left of the diagram. The cross-section touches the northern edge of the Ennerdale granite at the surface, and illustrates it as being at least 2km in thickness. This does not appear to be consistent with an earlier low-level aeromagnetic survey carried out over the same area. If this cross-section was a correct representation of the Ennerdale granite, we would expect to have seen a much clearer indication of this in the magnetic field data. The fact that this wasn’t apparent suggests that the Ennerdale granite is actually much thinner than shown.
This may be of particular relevance since the Ennerdale granite was identified by the MRWS geologist as a potential host rock. It is entirely within the Lake District National Park, which should be sufficient to rule it out, but given that the Dept. for Business Energy and Industrial Strategy (BEIS) have chosen not to protect National Parks, despite overwhelming opposition, this possible misrepresentation is a matter of particular concern. We are seeking expert advice on this point.
A missed opportunity
Regrettably, by designing this screening report to attract volunteers, RWM have failed in a number of areas as highlighted above. Any council or area which was predisposed to volunteering will probably take encouragement from the report covering their area, given that the only real screening criterion applied is the presence of one of three common rock types, meaning that virtually everywhere is considered to have suitable geology. Any council or area which is looking at this more objectively, perhaps for the first time, will struggle to make use of these reports, since the lack of information on relative suitability limits their value. If the end result is that only the same volunteers come forward once again, this exercise will have been an abject failure.
Cumbria Trust 
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