Email deadline - Please Send by 11.59pm on 28th February 2025
Urgent Request...
You may remember the seismic blasting of the Irish Sea to test the geology for a deep nuclear dump? - well they are back.
This time the investigations involve boreholes some if not all of which the regulators say can go ahead without any need for scrutiny or environmental permits. Regulators have written draft “guidance” for the developer ie His Majesty’s Government, which includes borehole drilling to test geology, including drilling through the seabed, for a gargantuan mine in which to dump very hot nuclear waste.
We have written a response to their consultation. The more responses they get the better - please do use our letter below for inspiration if you would like to write , the main thing to say is summed up in our conclusion:
This consultation and proposed ‘regulatory guidance’ is deeply flawed, dangerous and operating within an alternate reality. The alternate universe within which this consultation sits perceives Geological Disposal of Radioactive Waste as well understood and settled science - it is not. Geological Disposal is clearly an ongoing experiment with unacceptably wide margins for error on a catastrophic scale…..
Proposals include revised draft guidance on the requirements for authorisation (GRA) in England, Wales and Northern Ireland.
The consultation document can be viewed here: https://www.gov.uk/government/consultations/regulation-of-solid-radioactive-wastedisposal-facilities-proposed-guidance
Send by 11.59pm on 28th February 2025
Please email. Nuclear@environment-agency.gov.uk
For the attention of Trevor Howard, Environment Agency, Nuclear Regulation Group.
Dear Mr Howard,
Open consultation- Regulation of solid radioactive waste disposal facilities: proposed guidance
Radiation Free Lakeland are a volunteer nuclear safety group based in Cumbria and founded in 2008.
Support for Nuclear Free Local Authorities Response to Consultion. We fully support the response by the Nuclear Free Local Authorities to your consultation on guidance for various environment agencies regulation of “disposal of solid radioactive waste.” The regulators proposals include draft guidance on Near Surface and Deep Geological “Disposal.” The Nuclear Free Local Authorities response can be seen here: https://www.nuclearpolicy.info/wp/wp-content/uploads/2025/02/A429-NB315-Response-of-the-NFLAs-to-the-consultation-on-the-disposal-facilities-for-solid-radioactive-waste-Feb-2025.pdf
Consultation Premature by 100 to 500+ years. Radiation Free Lakeland say that this consultation is premature by 100 to 500+ years. This is clear given the ongoing experimental nature and growing body of ongoing research projects demonstrating the challenges of long term containment of radioactive wastes. These projects are looking at the challenges of containment before during and after closure.
Ongoing Research into known and unknown challenges to containment of radioactive wastes. Given the ongoing body of research throwing up ever more challenges to containment Is it legally and ethically prudent for the regulators to facilitate government policy to deliver a geological disposal facility? Are the regulators unable to hold the government to account for public safety by pushing for a moratorium on a GDF until such time as the research catches up with the policy?
Proposed Regulatory Guidance Panders to the Developer (His Majesty’s Government). The proposed guidance on the regulatory regime is clearly for the benefit of the developer of a GDF rather than to ensure public and environmental safety: “This guidance explains to developers and operators of radioactive waste disposal facilities the environment agencies’ numerical standards and 18 requirements for environmental permitting of solid radioactive waste disposal.” The developer is the UK Government who would employ commercial contractors to drill exploratory boreholes and mine a mass void. The contractors would be for example those listed by West Cumbria Mining’s preferred suppliers: AmpControl; rail freight provider Freightliner; Javelin Global Commodities; Parnaby Cyclones; Herrenknecht; Redcar Bulk Terminal; and Sandvik. West Cumbria Mining’s CEO is also employed by His Majesty’s Government as key advisor on GDF investigations and mining (Mark Kirkbride, Committee on Radioactive Waste Management)
Its an Experiment! The consultation asks: “Are the requirements and guidance on isolation and containment (requirements 8 and 9) clear and sufficient? If not, what improvements would you suggest“ Our response to this is that the regulatory guidance on construction of a geological disposal facility is premature and that the regulators should engage honestly with government and the public. There can be no “safe” containment while the research into very long term containment of very hot (200 degrees centigrade or more) radioactive wastes is still in its experimental stage and may remain so for many generations to come.
Mass Voids in Understanding. Requirement 9 states: “The aims of disposal are to contain waste and the associated radioactive substances (the subject of this requirement) and to isolate them (see requirement R8: Isolation) from the accessible environment so that there are no unacceptable consequences.” Given the ongoing research into containment and the known (and unknown) mass voids in understanding long term containment of radioactive wastes, this requirement cannot be fulfilled (unless the consequences of irreversible radioactive pollution are “acceptable” to the regulators).
The following are just a small sample of ongoing high level and critically important research projects….
Radioactive Gas An overview of gas research in support of the UK geological disposal programme. Gases will be generated in waste packages during their transport to a geological disposal facility (GDF), this generation will continue during GDF operations and after GDF closure. The range of gases produced will include flammable, radioactive and chemotoxic species. These must be managed to ensure safety during transport and operations, and the post-closure consequences need to be understood. https://www.cambridge.org/core/journals/mineralogical-magazine/article/an-overview-of-gas-research-in-support-of-the-uk-geological-disposal-programme/8F268D9BF5D5AE19BFA466B70F2D5B66
Understanding gas transport properties in mudstone. This current project is underway and will produce results that will facilitate the modelling of gas transport surrounding a geological disposal facility.. https://www.liverpool.ac.uk/earth-ocean-and-ecological-sciences/collaborate/disposal-of-nuclear-waste/
Onkalo Research Site ONKALO, the underground rock characterization facility in Olkiluoto, as part of the project “rock matrix Retention PROperties” (REPRO). The research site is located at a depth of 420 meters close to the repository site and the aim is to study the diffusion and sorption properties of radionuclides in the rock matrix in real in situ conditions..https://www.helsinki.fi/en/researchgroups/nuclear-waste-disposal/research
Long Term Research Programme. Long Term Research Programme for geological disposal of radioactive waste Work Programme 2020- 25 COVRA in collaboration with Technopolis Group https://www.researchgate.net/publication/347836713_long-term_research_programme_for_geological_disposal_of_radioactive_waste
Bentonite Erosion in a High Temperature Environment Understanding processes that could affect bentonite clay, and their potential significance, warrant further research studies – could such processes affect the bentonite’s long-term stability?https://www.gov.uk/government/publications/bentonite-in-a-high-temperature-environment-bentonite-erosion
Thermal Expansion of Engineering Materials and Surrounding Rocks. The heat released from the disposal of High-Heat-Generating Waste (HHGW) in a Geological Disposal Facility (GDF) will result in an increase in temperature, and therefore thermal expansion of both the engineering materials and surrounding rocks. The changes to the stress state arising from the thermal expansion of these materials, restrained by the surrounding rock mass, could affect several of the Thermal, Hydraulic, and Mechanical (THM) processes that operate after closure of a GDF. https://www.sciencedirect.com/science/article/abs/pii/S0013795223003058
International Research to Test Bentonite. Important roles of underground research laboratories for the geological disposal of radioactive wastes: an international perspective. For example, an experiment to test the in situ behaviour of bentonite will aim to expand the scientific knowledge on bentonite and sealing systems. https://www.lyellcollection.org/doi/full/10.1144/SP536-2022-97
Investigating the Thermo-Hydro-Mechanical Evolution of UK GDF. Investigating the thermo-hydro-mechanical evolution of a UK geological disposal facility due to disposal of high-heat-generating wastes https://www.sciencedirect.com/science/article/abs/pii/S0013795223003058
Tectonics, Seismicity, Volcanism. Tectonic and climatic considerations for deep geological disposal of radioactive waste: A UK perspective..Key processes considered in this paper include those which result from plate tectonics, such as seismicity and volcanism, as well as climate-related processes, such as erosion, uplift and the effects of glaciation.https://www.sciencedirect.com/science/article/pii/S0048969716314632
Decay Heat and Geological Integrity. Modelling a novel technique to remove excess decay heat from a geological disposal facility using a closed-loop geothermal system. Decay heat released from radioactive waste residing in a future geological disposal facility (GDF) poses many challenges, including long-term geological integrity and high temperature gradients in the rock. https://www.sciencedirect.com/science/article/pii/S245190492400708X
Heat Generating Radioactive Waste in Clay Formations THM-modelling benchmark initiative on the effects of temperature on the disposal of heat-generating radioactive waste in clayformations https://link.springer.com/article/10.1007/s11440-024-02502w
Extremophilic Microbial Metabolism and Radioactive Waste Disposal..Of particular interest are sulphate-reducing bacteria (SRB), which produce the corrosive species hydrogen sulphide that may compromise metal waste container integrity https://pmc.ncbi.nlm.nih.gov/articles/PMC10577106/
Mining Induced Seismicity Impact of mining-induced seismicity on land subsidence occurrence. https://www.sciencedirect.com/science/article/pii/S0034425723004868#:~:text=Mining%2Dinduced%20seismicity%20can%20damage,prediction%20capabilities%2C%20and%20associated%20consequences
The Danger of Coal Mining-Induced Earthquakes https://www.azomining.com/Article.aspx?ArticleID=1617
Reactivation and Mineralisation Associated with the Lake District Boundary Fault https://www.dur.ac.uk/media/durham-university/departments-/earth-sciences/mscr2024/LDFz_KM_MScR_24.pdf
Hideous Mockery The mass voids in understanding make a hideous mockery of the following: “Requirement 10: Construction, operation and closure.” The regulators clearly anticipate a wide margin of error saying “If you find that barriers are not installed or functioning as anticipated, you should assess the implications for the Environmental Safety Case. If necessary, you should take corrective actions to make sure that the claims made in your ESC can be fulfilled or modify your ESC accordingly to reflect the differences.”
Finally,
Boreholes. The consultation asks: “5. Do you agree with our proposed approach to permitting the sites for drilling boreholes during the surface-based intrusive investigations stage? 6. Is our approach to regulating the initial and subsequent borehole drilling activities during the surface-based intrusive investigations stage clear and fit for purpose? “
Our answer to both is “NO”.
Our reasons are:
Research into the containment of radioactive wastes is in its infancy making deep borehole investigations premature (see above).The consultation claims not to be site specific but clearly has Cumbria in mind with the worrying statement “Radioactive waste may arise if for example contaminated sediments on the seabed in an inshore environment are disturbed and brought to the surface by intrusive investigations.”
In the 1990s the Local Authority Cumbria County Council objected to boreholes facilitating a Rock Characterisation Laboratory at Gosforth under the Local Authority Planning regime. This scrutiny at a local level is no longer possible as a Geological Disposal Facility is now classed as Nationally Significant Infrastructure Project therefore overriding local authority planning.
Given this lack of local oversight the regulators should take on a more important role however there is breathtaking lack of oversight displayed in the following statement on seemingly arbitrarily chosen boreholes which would be exempt from regulation. “we will not regulate (under Schedule 23 of EPR 2016) boreholes that may be drilled to obtain geotechnical data to support construction of GDF surface infrastructure for example, waste package reception facilities. Similarly, we will not regulate trial pits or other excavations made to investigate characteristics of superficial deposits rather than geology that will prevent radionuclides passing to the surface”https://www.legislation.gov.uk/uksi/2016/1154/schedule/23
In Conclusion: We fully support the response by the Nuclear Free Local Authorities in particular:
10.1 Electricity producers should be required to demonstrate that they have investigated all means of generating electricity before resorting to producing more radioactive waste.
10.2 Disposal facilities should be monitored and there should be a capability to retrieve waste packages and waste if necessary.
10.8 The nuclear regulators should carry out an assessment of the radiological and collective dose implications of the various methods of radioactive waste ‘disposal’ including, for instance, incineration, disposal at existing landfill site, near surface disposal and deep geological disposal.
We sum up with the statement: this consultation and proposed ‘regulatory guidance’ is deeply flawed, dangerous and operating within an alternate reality. The alternate universe within which this consultation sits perceives Geological Disposal of Radioactive Waste as well understood and settled science - it is not. Geological Disposal is clearly an ongoing experiment with unacceptably wide margins for error on a catastrophic scale.
yours sincerely
Marianne Birkby
on behalf of Radiation Free Lakeland
(address supplied)
lakesagainstnucleardump.com a Radiation Free Lakeland campaign
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