AECOM, aquifer, Arctic, AREVA, cancer, clean water, climate change, coastal erosion, cumbria, Cumbrian aquifer, dangers of nuclear, Drigg, Drigg geology, EDF, Engie, environment, France, GDF-Suez, Ireland, Irish Sea, Isle of Man, land slip, land undercut, landslide, Mann, NHS, Norway, nuclear, nuclear energy, nuclear industry, nuclear power, nuclear reactors, nuclear safety, nuclear waste, plutonium, radiation, radioactive beach, radioactive waste, rising sea-level, risk management, Scotland, Sellafield, Studsvik, sudden slip failure, Toshiba, UK, URS, water, WIPP
For information on how to oppose Drigg see: https://mariannewildart.wordpress.com/2016/07/03/lock-the-gate-on-drigg-nuclear-waste-site-15th-july-in-kendal/
“The Low Level [Radioactive] Waste Repository (LLWR) is situated near to areas of Cumbrian coastline where historical evidence indicates that the coast has receded in the past, and as it is anticipated that sea level will rise, it is expected that the repository area will be disrupted through coastal erosion and sea-level rise will accelerate this process.” (NDA, 2015)
Rusting Shipping Containers Storing Radioactive Waste At Drigg Near the Irish Sea
Looking at the picture above, it doesn’t take much imagination to see that the LLW Nuclear Waste Dump at Drigg will fall onto the beach and eventually into the Irish sea, (unless it’s moved). Official documents even say so. It’s not a matter of if, only how quickly.
“LLW Repository, Holmrook, Cumbria: Coastal Erosion Summary, Version 2, January 2015”, NDA-OGL
Who benefits from this dump along the coast of the Irish Sea? The operators, who are a consortium of California based URS (AECOM), Swedish Studsvik, and French State owned AREVA. British Serco is an affiliate. (https://www.gov.uk/government/organisations/nuclear-decommissioning-authority/about ) Also, French State owned EDF, which operates the UK’s nuclear reactors benefits from (presumably) cheaper disposal. Japan’s Toshiba and French Engie (GDF-Suez) may benefit from it, if they succeed in building new nuclear reactors at Moorside. More cheaply disposed, however, may simply mean more profits for the operating consortium, rather than cheaper disposal cost for EDF.
Who is liable for moving the waste to keep it from falling into the Irish Sea? The site is privately operated but government owned. Hence, ultimate liability falls upon the British government (i.e. taxpayer). If the Drigg dump is allowed to fall into the sea, it will impact the UK, Isle of Man, Ireland, and Norway, the Arctic and more. The Drigg dump is only 500 meters from the coast at high tide. The only true option is to move it away from the coast. By continuing to fill it up, there’s just more to move later.
The Nuclear Decommissioning Authority (NDA) is owned by the British Government and the majority of its funding comes from the government.
Excerpts from: “LLW Repository, Holmrook, Cumbria: Site Optimisation and Closure Works Coastal Erosion Summary, 0 RP/340737 /PROJ/00032, Version 2, January 2015” © NDA-Crown-OGL:
“The Low Level Waste Repository (LLWR) is situated near to areas of Cumbrian coastline where historical evidence indicates that the coast has receded in the past, and as it is anticipated that sea level will rise, it is expected that the repository area will be disrupted through coastal erosion and sea-level rise will accelerate this process.” p. 6
Due to the long-term nature of the site the long-term liabilities could exceed many of the organisations where that liability currently resides. At the present time all liabilities associated with the operation of the site reside with LLW Repository Ltd.
However, the LLWR site is owned by the Nuclear Decommissioning Authority (NDA). By virtue of its classification as a “Designated Site” under the Energy Act 2004, responsibility for the site rests with the NDA. Section 21 of the Energy Act 2004 gives the NDA financial responsibility for the decommissioning, operation or cleaning up of designated installations, facilities and sites. As there are no “sunset provisions” in the Energy Act 2004, the NDA would continue to be responsible for the future costs of carrying out its responsibilities until such time this legislation is amended or repealed.
This responsibility would be independent of the completion of processes to surrender the Environmental permit and/or delicense the nuclear site, as the repository would remain a “Designated Site” under the Act.
Notwithstanding this, CIRIA publication C718, includes the route map for identifying the roles and responsibilities in relation to the management of landfills affected by coastal erosion and emphasises the “polluter pays” principle.
If the environmental permit has been surrendered and the “polluter” in this case LLW Repository Ltd, or its successor no longer exists then the regulator, in this case the Environment Agency would become the enforcing authority and hold the responsibility to minimise harm, However, as stated above the liability is retained by the NDA“. (pp. 12-13)
“At present the repository area, including the area for future vaults, lies at about 500m from the high water mark, and a period of at least several hundred year is expected before the erosion of the facility could commence and will not be able to without large scale detectable changes to the coast taking place.” (p. 7)
The following claim is both meaningless and appears false: “During much of the time both the Sellafield and LLWR sites will remain under regulatory control, and the site operators will be obliged to monitor coastal changes and carry out work to progressively refine projections for the longer-term evolution of the coast.” (p. 7) How long? 25 more years? 50 more years? This isn’t “much”, unless they expect it to collapse much sooner than 300 years. And, what good is monitoring and projections? The real cost will be in protecting it or moving it elsewhere. Better to move it now.
Some of the waste will still be lethal:
“As stated above the precise timescale over which disruption by coastal erosion might occur is uncertain, however, the characteristics of the disposed waste inventory are such that, following the initial decay of shorter lived radionuclides within the waste, (within the first 300 years or so), there will be little additional decline in the residual hazard up until the time disruption occurs. After about 300 years, features that might delay disruption by additional decades, or even hundreds of years will thus not have a large effect on the radiological impact when disruption occurs.
As the primary mechanism of disruption is expected to be erosion by under-cutting at the base of the sea cliff (most likely below the base level of the vaults), engineered features of a near-surface vault disposal system are not expected to offer significant protection.
Any shoreline or coastal defences to protect against threats from coastal erosion or inundation would need to be continuously maintained over a substantial period in order to be effective in risk mitigation (this is impossible to substantiate and would be inconsistent with the regulatory principle that unreasonable reliance on human actions to protect the public and the environment should be avoided). Given the difficulty of identifying engineering measures that can provide effective passive control against threats from coastal erosion and inundation, safety arguments in the ESC ultimately centre on the overall acceptability of disposal itself.” pp. 8-9 “LLW Repository, Holmrook, Cumbria: Site Optimisation and Closure Works, Coastal Erosion Summary”, 0 RP/340737 /PROJ/00032 , Version 2 . January 2015” © Copyright NDA-OGL:Crown http://llwrsite.com/wp-content/uploads/2015/12/Appendix-K2-Coastal-Erosion-Summary.pdf (Emphasis our own; NDA Image at Top of this post is also from the document). https://www.nationalarchives.gov.uk/doc/open-government-licence/version/3/
Based on CIRIA publication C718 discussed above there appears a small possibility that the operator might be held liable if there is a sudden slope failure earlier than expected, while Drigg is still open. The companies would probably just declare bankruptcy, however, still leaving the taxpayer liable. When it is believed that slope failure is imminent, you can be certain that no private operator will be found.
Ireland has lost as much as 2 meters (a little over 6 feet) off of its coast within a few months due to storms: http://www.independent.ie/irish-news/ireland-250-acres-smaller-after-floods-tear-chunks-off-coastline-30077305.html
The Drigg Dump Also Menaces Regional Groundwater
Image from “LLWR Lifetime Project: Sorption parameters for the LLWR geosphere prepared by Nexia Solutions for Low Level Waste Repository Site Licence Company. © Copyright belongs to NDA, OGL-Crown. (08) 9451 Issue 1 Date: Sept. 2008. http://llwrsite.com/wp-content/uploads/2013/04/1_-9451-Sorption-Parameters-for-Geosphere-KD-Issue-1-MASTER-01-02-11.pdf
From “About the NDA“:
“The Department for Energy and Climate Change and HM Treasury set our annual operational budget. Our budget is a combination of government funding and income from our commercial assets.
We recognise that there are always competing demands on public finances. This means we have to prioritise the programmes of work across our estate. We use a set of criteria that balance hazard reduction, value for money and making progress on a broad front.
We also aim to maximise the commercial value of our assets. This helps to offset the costs of the decommissioning programme. As our income-generating assets come to the end of their lives, our reliance on public funds increases.
The total planned expenditure for the financial year 2016 to 2017 is £3.2 billion of which:
* £2.25 billion is government grant-in-aid
* £0.9 billion is income from commercial operations
We expect our annual expenditure for 2016/17 to be:
* £3 billion on our site programmes
* £0.2 billion on non-site activities, including:
* skills development
* research and development
* pension costs
* fees to Site Licence Companies (SLCs)
* implementing geological disposal
* NDA operating costs
Low Level Waste Repository (LLWR)
The repository near Drigg in west Cumbria has operated as a Low Level Waste (LLW) disposal facility since 1959. The site has … disposed of the nation’s low level waste for more than 50 years. Containerised waste is grouted prior to disposal in engineered concrete vaults. LLW is produced by UK nuclear facilities and non-nuclear sources such as hospitals, research establishments and other industries.
Increasing amounts of LLW are now being channelled through a range of alternative waste management options, re-use and metals recycling, that are helping to extend the life of the repository.”
[Reuse and recycling may extend the space in the dump but it may shorten the life of the user of the recycled radioactive metal.]
Cheaply done disposal may, or may not, benefit the NHS in the short-term, but may bankrupt the UK’s National Health Services (NHS) in the long-term due to increased cancer rates during Drigg’s existence and if Drigg is allowed to fail (fall). Drigg’s failure will impact Scotland, the Isle of Man, Ireland, and eventually Norway and the Arctic and impact their health-care systems and cost them clean-up money, unless they shift the cost back to the UK. [Update-clarification: Someone wondered if the first NHS was a typo. No it is not. What it is meant to cover is the argument that the NHS might save money for medical waste disposal. The theoretical argument is do it cheaper and the client saves. This isn’t necessarily so, however. The for-profit disposal companies may be the only financial winners even in the short term. Most likely both Scotland and England’s NHS send waste to Drigg. While medical radioiodine is short-lived, Technetium 99 m becomes very long-lived and dangerous Technetium 99. Thus, this is not proper disposal.]
For Drigg: “Parent Body Organisation (private sector consortium): UK Nuclear Waste Management Ltd (URS, Studsvik, Areva, with Serco as an affiliate) – Contract awarded 2008 (renewed in 2013)” OGL: https://www.gov.uk/government/organisations/nuclear-decommissioning-authority/about
Two of the consortium members running the Drigg radioactive waste dump – URS and AREVA- were consortium members at the WIPP nuclear waste dump when it had major problems with emissions of radiation into the environment.
This was before AECOM bought URS, however. In this Drigg Consortium list Serco Assurance is also mentioned. This appears to be the notorious UK Serco: https://en.wikipedia.org/wiki/Serco
Areva would be out of business if it were not French State owned.
Explains how more cheaply made disposal is/was proposed to help the nuclear industry: https://www.theguardian.com/environment/2010/jan/11/nuclear-radiation-risks
“The Forecast for UK’s Coast: Radioactive”
Published on Monday, April 21, 2014 by Common Dreams
“Environment Agency warns “the expected evolution scenario” for nuclear dump in Cumbria is flooding, erosion by Andrea Germanos, staff writer” http://www.commondreams.org/news/2014/04/21/forecast-uks-coast-radioactive
Did this 2014 document differ from the current one?