For "Decommissioning" Read Dumping Radioactive Wastes to Air, River, Land and Sea.

Sellafield boasts that it is making the most hazardous place in Europe “safe” and “clean” by its decommissioning work. What this means in reality is the dispersal of nuclear wastes to the environment. The seismic blasting was the first step in the push to get shot of high level nuclear wastes under the seabed off the Lake District coast in a so called "geological disposal facility" aka hot nuclear dump.

In order to get shot of its less hot but still hazardous decommissioning wastes on site that include the infamous Windscale chimney Sellafield have applied to the Environment Agency for a “Permit Variation.”

The Environment Agency is now consulting on a wide range of unrelated asks from Sellafield in the same Permit- a nuclear waste dumping “smorgasbord’ which includes a new discharge to the river Calder, a increase in the coastal radioactive landfill on site which includes “hotspots” of tritium, a new chimney stack for radioactive gases and the removal of reporting limits on a number of radionuclides because it is “too complicated’.

The issues are serious enough to be separate consultations rather than lumped together under misleading headings- each should be a standalone application from Sellafield rather than lumped together in a single Permit Variation.

Please write to the Environment Agency (see below) urging them to go back to Sellafield to redo this “Permit Variation” consultation which is not fit for purpose due to the lumping together of issues which should be separate applications and to the lack of information on issues such as environmental impacts.

The submission to the Environment Agency from Lakes Against Nuclear Dump, Close Capenhurst and Nuclear Free Local Authorities is below. Please do use this as inspiration to write your own objections and ask them to go back to Sellafield and demand new fully referenced Permit Applications on which there can be public debate about the increasing dispersal of radioactive waste to our environment.

• To the Environment Agency Wednesday 23 August 2023 Nuclear Regulation Group By email to nuclear@environment-agency.gov.uk CA20 1PG, Sellafield Ltd, Sellafield site- EPR/KP3690SX/V013: Radioactive Substances Activities (RSA) Environmental Permit Variation Consultation 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 Close Capenhurst Campaign which seeks the closure of the Capenhurst Uranium enrichment plant, but campaigns more widely upon nuclear transport and radiation issues.

  • The Nuclear Free Local Authorities which is a network of affiliated local authorities and elected members opposed to nuclear power

LAND first became aware of this consultation via the online media outlet Cumbria Crack whose reporting repeated the misleading nature of the “Permit Variation” as described by the Environment Agency and Sellafield. This consultation and “Permit Variation” lumps together entirely different and very significant developments on the Sellafield site which should be subject to separate Permit Applications with fully explained and comprehensively referenced consultations. RETROSPECTIVE PERMIT APPLICATION FOR NEW GASEOUS DISCHARGE ▪ Registration of the Magnox Swarf Storage Silo Retrievals Ventilation System (MSSSRV) stub stack which is being constructed to minimise and reduce facility gaseous discharges during operational activities by improving gaseous abatement with the use of additional High Efficiency Particulate Air filters.

The ‘Registration of the Magnox Swarf Storage Silo Retrievals Ventilation System sub stack’ appears to be a retrospective application for an onsite development that has already taken place.

There are no comprehensive details within the consultation of existing gaseous discharges from the MSSSRV or detailed proposed additional gaseous discharges from the ‘new’ sub stack. Infact Sellafield state that: ‘MSSS will need to be considered as a new plant until operational data are gathered. Therefore this paper will consider the most appropriate approach when setting the Plant Notification Levels in the absence of actual operational discharge data for the new ventilation system’. Sellafield acknowledge that Plant Notification Levels from across the site will be exceeded because of ‘routine operational variability at an approximate rate of four a year’. Sellafield are estimating the levels for which they are asking for this Permit Variation for what ‘will need to be considered a new plant until operational data are (sic) gathered’. We note that Caesium-137 (Cs-137) and Strontium-90 (Sr-90) are the two named radionuclides for the Predicted Retrievals Ventilation System annual gaseous discharges and associated off site public dose with other radionuclides merely lumped in as Alpha and Beta.

According to the US Centres for Disease Control website referencing the potential health impact of exposure to Cs-137: ‘can increase the risk for cancer because of exposure to high-energy gamma radiation. Internal exposure to Cs-137, through ingestion or inhalation, allows the radioactive material to be distributed in the soft tissues, especially muscle tissue, exposing these tissues to the beta particles and gamma radiation and increasing cancer risk’ and exposure to Sr-90: ‘can be inhaled, but ingestion in food and water is the greatest health concern. Once in the body, Sr-90 acts like calcium and is readily incorporated into bones and teeth, where it can cause cancers of the bone, bone marrow, and soft tissues around the bone’. We note that the New Predicted Retrieval Ventilation System Plant Notification Levels appear to be much higher than the Permit Registrations for Withdrawal for Alpha emissions and for Cs-137.

This is at odds with Sellafield’s assertion that as reprocessing has stopped so emissions will be far less.

In our view, this Permit Variation should be a standalone application from Sellafield with much more information provided in layman’s terms to the public and to consultees. Plutonium 239 (Pu-239) is included as a ‘long term gaseous dose release ratio along with Cs-137 and Sr-90 in the table ‘Appendix 3 - Dose Calculations to Infant, Child and Adult.’ Again, experts at the CDC can furnish us with an explanation of the impact of Pu-239 with a warning that: ‘plutonium is most dangerous when inhaled. When plutonium particles are inhaled, they lodge in the lung tissue. The alpha particles can kill lung cells, which causes scarring of the lungs, leading to further lung disease and cancer. Plutonium can enter the blood stream from the lungs and travel to the kidneys, meaning that the blood and the kidneys will be exposed to alpha particles. Once plutonium circulates through the body, it concentrates in the bones, liver, and spleen, exposing these organs to alpha particles. Plutonium that is ingested from contaminated food or water does not pose a serious threat to humans because the stomach does not absorb plutonium easily and so it passes out of the body in the faeces’.

As it is our view there is no safe exposure limit so too it is our contention that, in the case particularly of Pu-139, there should be zero Plutonium release from the Magnox stacks.

We note that HEPA (High-Efficiency Particulate Air) filters were developed in the 1940s as part of the Manhattan Project in Los Alamos during World War II. HEPA filters which need to be changed regularly and stored carefully with temperature control are capable, it is claimed of “theoretically” (US Environmental Protection Agency) removing most particles above 0.3 microns if the filters are stored properly, working properly and in a non-corroded housing. 'HEPA' is not regulated in the UKwith air purifiers advertised as 'HEPA air purifiers', even though their whole system filtration efficiency is well below the HEPA filtration efficiency. We note that some HEPA filters may not have the necessary durability to withstand the effects of elevated levels of radiation.

The filter material breaks down when exposed to radiation, compromising the air purifier’s ability in filtering out radioactive particles.

To repeat: There are no details within the consultation of existing gaseous discharges and proposed gaseous discharges from the ‘new’ sub stack. There is no indication of HEPA filtration regime of quality, correct storage, application, leakage monitoring or where the used HEPA filters containing the (unrevealed to the public) gaseous discharges would be dumped. This makes the consultation null and void as it is impossible for the public and organisations to make any meaningful comment of support or opposition without any relevant information.

NO MONITORING OF OUTFALL X TO RIVER CALDER ▪ Registration of an Outfall X to discharge construction related aqueous waste arisings (non-sewage trade waste) to the River Calder via surface water drainage.

This new development is lumped into the same “Permit Variation” as the new sub stack on the Magnox Swarf Storage Silo Retrievals Ventilation system. There is no indication of whether this is a new Outfall or an existing Outfall into the River Calder.

The only detail provided is in a letter from Sellafield to the Environment Agency dated 30th June 2023 : ‘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 (ensuring the application of BAT) and will not be subject to any monitoring or discharge reporting against Site limits.’ (Sellafield) proposes that Outfall X be added to pre-existing pre-operational measure S1.3B.5 – alongside the Factory Sewer and Calder Interceptor Sewer - which states that: ‘The Operator shall submit proposals for any new engineered routing of aqueous radioactive waste via the Calder Interceptor Sewer or Factory Sewer, including a report which demonstrates how best available techniques (BAT) will be used to minimise the activity of discharges of aqueous radioactive waste to the environment and to minimise its radiological effects on the environment and members of the public. These proposals will require approval in writing from the Environment Agency prior to such disposals being made.’ There is no report available to the public within this consultation on the existing range and activity of radioactive discharge to the River Calder via the Interceptor Sewer or Factory Sewer.

Worryingly Sellafield say that the ‘new’ Outfall X into the Calder ‘will not be subject to any monitoring or discharge reporting against Site limits” as it is their “intention” that “any radioactivity present will be below typical limits of detection.’ This is outrageous. Only Sellafield could apply nonchalantly to discharge contaminated aqueous waste which may or may not also contain radioactivity.

CUMULATIVE DAMAGE TO RIVERS EHEN AND CALDER The Rivers Ehen and Calder have two adjoining catchments in West Cumbria with similar features. The River Ehen flows from Ennerdale Water. The river is famously designated as a Special Area of Conservation (SAC), due to supporting the largest freshwater pearl mussel population in England, and to the prevalence of Atlantic Salmon. Great expense has gone into preserving the fresh water pearl mussel with a new £300 million pipeline from Thirlmere designed to protect the River Ehen. The river Ehen’s last reaches run parallel to the Irish Sea which it joins at Sellafield at the same point as the River Calder whose last reaches have been canalised in order to more quickly get shot of the contaminated runoff and discharge from the site. There is no consideration whatsoever of the cumulative impacts of additional discharges to the River Calder and to the mouth of the River Ehen within this consultation from Outfall X. RADIOACTIVE PARTICLES: DANGER TO HEALTH We do not subscribe to the view that there is a safe limit to exposure to radioactivity. In their submission to the recent DESNZ consultation on ‘Managing Radioactive Substances’, the NFLAs included the following wording ‘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’. NCRP concludes 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 short – there is a scientific consensus that there is no safe level of radiation. 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. And it is not just cancer risks that should concern us. A recent meta-analysis on ionising radiation and cardiovascular disease published in the British Medical Journal (BMJ) concluded that: ‘Our findings suggest that radiation detriment might have been significantly underestimated, implying that radiation protection and optimisation at low doses should be rethought.’ And also: ‘This finding has considerable implications for the system of radiological protection. [The] added risk would nearly double the low dose detriment.’ Commentary No. 27 – Implications of Recent Epidemiologic Studies for the Linear-Non-threshold Model and Radiation Protection, NCRP 2018 https://ncrponline.org/shop/commentaries/commentary-no-27-implications-of-recent-epidemiologic-studies-for-the-linear-nonthreshold-model-and-radiation-protection-2018/ BMJ 8th March 2023 https://www.bmj.com/content/380/bmj-2022-072924’ On 16th August 2023, the BMJ published a further study identifying, that in a large study group of nuclear industry workers, there was found ‘an excess relative rate of solid cancer mortality’…than ‘estimates currently informing radiation protection, and some evidence suggests a steeper slope’….’in the low dose range’. This further reinforces the belief that there are no safe radiation limit and that exposure to any nuclear industry generated radioactivity in the environment – especially if prolonged - will compromise the health of the general population. BMJ 16th August 2023 https://www.bmj.com/content/382/bmj-2022-074520 For almost ten years, volunteers at Radiation Free Lakeland have been taking soil and sand samples from the beaches adjoining Sellafield in West Cumbria and sending these to the United States for testing at a professional institute. Due to a lack of available funding, the group could only afford to commission the institute to test for two isotopes - americium and caesium. In 2018, undergraduate nuclear science students from the Worcester Polytechnic Institute in Massachusetts compiled the results into an initial report: ‘Of the 36 samples tested 10 (28%) were found to be over the safety limit for Caesium and 14 (39%) were found to be over the safety limit for Americium.’ That needs restating. Fully one third of all random samples physically taken (i.e. not simply scanned with a Geiger counter) from West Cumbria’s coastal areas including the Cumbrian beaches said to be ‘pristine’ and ‘safe bathing beaches’ were found to exceed the supposed recommended safe levels for Americium- 241 and Caesium-137. On a speaking tour of West Cumbria hosted by Radiation Free Lakeland in 2014, the former US nuclear industry regulator Arnie Gundersen said: “Some of the samples I took back then were as radioactive as Fukushima. “It is important to note that this beach radiation was NOT found by prospecting with a Geiger counter looking for hot spots. Rather, citizen scientists just took dirt/sand samples randomly between the low and high tide marks and then mailed the samples with a GPS location to be analyzed here in the US. “The UK government has been covering up the severity of the radiation in the Irish Sea and on Cumbria’s beaches”. https://mariannewildart.wordpress.com/2018/07/06/health-warning-for-cumbrian-beaches/ In October 2004 the Nuclear Free Local Authorities Steering Committee agreed a set of clear environmental principles which should be used for the management of nuclear waste. These long-standing principles have stood the test of time and remain as relevant now as when they were agreed by the NFLA. These are:

• The idea that radioactive waste can be "disposed" of be rejected in favour of radioactive waste management;

• Any process or activity that involves new or additional radioactive discharges into the environment be opposed, as this is potentially harmful to the human and natural environment;

• The policy of 'dilute and disperse' as a form of radioactive waste management (i.e. discharges into the sea or atmosphere) be rejected in favour of a policy of 'concentrate and contain' (i.e. store safely on-site);

• The principle of waste minimisation be supported;

• The unnecessary transport of radioactive and other hazardous wastes be opposed;

• Wastes should ideally be managed on-site where produced (or as near as possible to the site) in a facility that allows monitoring and retrieval of the wastes.

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.’ With its own policies, and the stated DESNZ key considerations in mind, the Nuclear Free Local Authorities wish to join LAND in recording their strong objections to the continuance of policies that permit Sellafield to discharge radioactive materials into adjoining rivers, other waterways, or the atmosphere. Whether the waste is radioactive or chemical, or contaminated silty-run off from decommissioning, there is going to be a cumulative impact on the last reaches of the River Calder and the River Ehen, on the beaches of West Cumbria, and (potentially) upon local inhabitants.

REMOVAL OF “VERY COMPLICATED AND TIME CONSUMING” MONITORING The removal of the Gaseous Annual Site Limits for Krypton-85 & Antimony-125 following the completion of Magnox reprocessing in July 2022.

• Sellafield request to halt monitoring of emissions Krypton-85 & Antimony-125.

The reasons given are that, since the end of Magnox bulk reprocessing (July 2022) gaseous discharges of these materials will reduce significantly, and Sellafield claim: ‘It should be noted that the sample collection and analysis of Kr85 from environmental concentrations at the met station on site is very complicated and time consuming, in fact it makes the dominant contribution to the analytical requirements for the environmental monitoring programme’. According to the ‘US Environment Pollution Centres’ website, Krypton-85 is a colourless, odourless, and tasteless gas that emits low levels of gamma and beta radiations. It is one of the 5 radioisotopes of krypton and has a half-life of 10.756 years. Krypton-85 is highly toxic and may cause cancers, thyroid disease, skin, liver, or kidney disorders. And according to the ‘US National Library of Medicine – National Centre for Biotechnology Information’ website, long-term inhalation of antimony can potentiate pneumoconiosis, altered electrocardiograms, stomach pain, diarrhoea, vomiting, and stomach ulcers, results which were confirmed in laboratory animals. ‘Its biological monitoring in the workplace is essential’. We believe that the overriding concern in any environmental monitoring regime should be an absolute regard for the protection of human beings and our environment. This application if granted will discharge Sellafield from this duty with respect to gaseous discharges of Krypton-85 and Antimony-125 because it is an ‘inconvenience’ to the business rather than no longer ‘necessary’ for human or environmental protection. Accordingly, we are opposed to the granting of this application. Surely with all the university clusters which work collaboratively with the nuclear sector, and the enormous funding streams involved, there could be additional monitoring regimes in place for work that Sellafield wants to ditch because it feels it is ‘very complicated and time consuming’? And surely the continuance of monitoring will enable them to maintain and improve their expertise, if nothing else? As there will still be Krypton-85 and Antimony-125 discharged into the atmosphere we are also concerned that this consultation is unable to provide information (apart from Sellafield’s own guess) as to what exactly would be coming out of the new Magnox Swarf Storage Silo Retrievals Ventilation System stacks.

CALDER RADIOACTIVE LANDFILL EXPANSION NEAR IRISH SEA - DISINGENOUS HEADLINE IS “REDUCTION TO RADIUM-226 LIMIT” A reduction to the Radium-226 limit and update to the site plan due to Sellafield Ltd’s application to extend the Calder Landfill Extension Segregated Area into an adjacent ‘valley area’. There are no required changes to the site’s RSA environmental permit site boundary. Again this ‘Permit Variation’ lumps in another expansion of the Calder Landfill with all of the above and the red herring of ‘a reduction to the Radium-226 limit’. The reduction to the Radium 226 limit is welcome but is less than a drop in the ocean when compared to the increase in Tritium and other radionuclides going into the Calder Landfill and subsequently into the Irish Sea from leachate and from acknowledged inevitable erosion. Because of the decommissioning of Sellafield’s Pile 1 and 2, and the expediency of getting shot of the wastes on the Sellafield site, a new landfill area called Calder Landfill Extension Segregated Area Disposals (CLESA) for nuclear waste dumping was created in 2017. CLESA is located on the south-western corner of the Sellafield site, adjacent to the confluence of the River Calder and River Ehen. “This Best Available Techniques (BAT) justification demonstrates that the environmental permit for CLESA should be varied to allow it to accept radioactive waste material with higher levels of tritium.” Despite the Environment Agency previously pointing out in 2014: “it is doubtful whether the location of the LLWR site (at nearby Drigg) would be chosen for a new facility for near-surface radioactive waste disposal if the choice were being made now. It would not be in accordance with current national and international siting practice for new facilities.” CLESA is in the south-western corner of the Sellafield site, in the north-western part of the Calder Floodplain Landfill just a few metres from the Natterjack Toad Ponds and the Irish Sea. LANDFILL MISSION CREEP - MORE RADIOACTIVITY AND MORE WASTE TO ACCOMMODATE DEMOLITION OF WINDSCALE PILES. In 2015 Sellafield’s permit limit to a much smaller landfill on site was 37 Bq/g. This increased with the enlarged CLESA landfill to 200 Bg/g in 2017. Allowance was made for ‘hot spots’ as decommissioning has led to larger volumes of bulk decommissioning wastes, including bricks and large concrete blocks. ‘The Pile 1 fingerprint informs the assessment of the potential impacts of particles, and surface contaminated blocks. It was decided to assume a maximum ‘hotspot’ / surface activity of 40,000 Bq/g.’ (CLESA PCRSA Review Report December 2017 page 28) TRITIUM ‘Sellafield has a number of items where the radioactivity is dominated by tritium which will need to be disposed in the coming years…This Best Available Techniques (BAT) justification demonstrates that the environmental permit for CLESA should be varied to allow it to accept radioactive waste material with higher levels of tritium’. From an original permit of 37 Bq/g, ‘hotspots of 40,000 Bq/g H-3’ were asked for by Sellafield in their ‘Best Available Techniques Justification’ for the Calder Landfill Extension. This was approved by the Environment Agency. Liquid effluent from the landfill which includes Tritium Leachate goes to the Calder Sewer and other Outfalls to the Calder and then into the mouth of the Ehen and the Irish Sea. When the approval for the original Calder Extension with its enormous Tritium capacity was given in 2017 the impacts of Tritium were not widely understood, despite being flagged up by scientists such as Dr Ian Fairlie. Now in 2023 Tritium is known to be much more harmful to human and non-human health than was previously assumed by mainstream academia. This nonchalance about Tritium is now changing. The consequences of low-dose exposure known to trigger devastating biological effects are reported by scientistscontributing to the Journal of Radiation Research and calls for a global effort to assess the full impacts of tritium. There should be no further extension to the Calder Landfill. The CLESA Valley Development would increase the volume of the landfill by 23%. GROUNDWATER AND RADIOACTIVE LANDFILL The US Vermont Yankee Nuclear Power Station reactor was permanently shut down on December 29th 2014largely due to the contamination of groundwater by Tritium. We note that the groundwater at Sellafield is already contaminated with radionuclides: ‘The distribution of elevated total alpha shows that it is concentrated around known areas of concern ….this indicates a common source term associated with a potential localised leak or spill’. https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/705993/Groundwater_Monitoring_at_Sellafield_-_Annual_Data_Review_2016.pdf This is ongoing: ‘Sellafield Ltd are seeking ideas, innovations and technologies that will deliver game changing solutions to prevent or minimise leaks from the Magnox Swarf Storage Silo (MSSS) Compartments 1 - 6. Current leak rates are circa 1.5 – 2.5 m3/d. It is desirable to reduce these as much as possible’’. https://www.gamechangers.technology/challenge/Leak_prevention_or_minimisation Sellafield lies above the West Cumbria Aquifer which supplies West Cumbria with drinking water from boreholes near Egremont and elsewhere. SCENARIOS EXCLUDE INDUCED EARTHQUAKES Sellafield’s PCRSA Addendum for the CLESA Valley Development goes into detail on projected releases from the Calder radioactive dump, for example coastal erosion exposing the giant blocks of contaminated concrete and making a new headland which fishermen might use, or the building of a house on the landfill site; however, ‘radionuclide leaching during the operational phase was excluded’ from the modelling of future scenarios. Also excluded from the modelling was the impact of anthropogenic earthquakes. There are currently plans in development to establish the first deep coal mine in the area and to locate a Geological Disposal Facility (GDF) for high level nuclear wastes; both of these developments near Sellafield would produce induced earthquakes as a matter of course. Lakes Against Nuclear Dump have called for a traffic light system for Coal Induced Earthquakes Near Sellafield. The limit of Peak Particle Velocity that Mark Kirkbride, the CEO of West Cumbria Mining (and also the Government’s advisor on GDF construction) wants the earth movement limit for his mine to be set at 6mm/sec, this is as high as the upper limit for blasting in a quarry. Even then, unlike fracking which would be halted at a much lower level, the operations would continue. The vibrations of huge bolter mining and cutting machinery in multiple coal mining operations under the Irish Sea would be continuous rather than sporadic as in blasting. At the Chaco National Heritage Park in New Mexico, the limit is advised at 2mm/sec PPV for mining to protect the structures https://pubs.usgs.gov/of/1985/0529/report.pdf. It is accepted that at 1.0mm/sec PPV the level would cause complaints from the public. CEO Mark Kirkbride wants his “accepted” level to be 6mm/sec of Peak Particle Velocity. Unlike fracking, West Cumbria Mining do not propose stopping operations even if earthquakes of a far greater magnitude than 0.5 ML occur. Coal mining is known to induce earthquakes of 3 ML and more which could also induce liquefaction of the Sellafield site. Liquefaction is another scenario which has not been taken into account in relation to the CLESA Valley Development despite obvious concerns about liquefaction impacts on Sellafield structures. In conclusion, in our view, this is a consultation ‘smorgasbord’ with the EA seeking views on a wide range of unrelated ‘asks’ made by Sellafield of the agency to vary its operating permit. Consequently, it is quite confusing to identify all the relevant issues to which the EA is seeking a response and in any case the information provided is completely inadequate to enable respondents to do so, for example being short on historic data relating to discharges against which to compare the new proposed limits. It would be easy to ‘miss the wood for the trees’ as many respondents will feel overwhelmed and over-faced by the many elements constituting the application–cynics might suggest this is a strategy designed to benefit the applicant. In our view, these items should have each been submitted separately. The issues are serious enough –discharges of radioactive materials into the atmosphere and local watercourses, the removal of a requirement to monitor atmospheric discharges for radioactive elements, and an extension to the landfill site for nuclear waste dumping - each should be a standalone application from Sellafield rather than lumped together in a single Permit Variation. The information provided to the public is not fit for purpose. Each element for a variance in permit should have been accompanied by an explanation in layperson’s term (rather than nuclear industry ‘speak’) of what the change amounts to as opposed to the current position, the rationale (if any, other than business expediency) for the proposed changes, and historic discharge data for comparison with the limits sought going forward. We urge the Environment Agency go back to Sellafield and demand that the issues each be presented as independent and separate Permit Applications with fully referenced, accessible information to present to the public and to consultees to enable them to properly consider them and thereafter submit their considered responses. We oppose the Permit Variation for these, and all the previously stated, reasons. Thank you for considering our application. 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, Land Against Nuclear Dump Martyn Lowe, Close Capenhurst Campaign Councillor David Blackburn, Chair, Nuclear Free Local Authorities, English Forum Sent by Richard Outram, BA (Hons), Secretary, UK/Ireland Nuclear Free Local Authorities and Mayors for Peace Chapter Secretary, City Policy, Manchester City Council Richard.outram@manchester.gov.uk

The late great Kevin Carr and "Trains and Boats and Planes are Bringing Nuclear Waste to My Home..."