A Letter from Radiation Free Lakeland to Cumbria County Council.
On July 2 last year, Radiation Free Lakeland wrote to the leader of Cumbria County Council to vehemently oppose a plan for the first deep coal mine in the UK in 30 years.
I am writing again on behalf of Keep Cumbrian Coal in the Hole which is a Radiation Free Lakeland campaign, to add further comments, and also ask to be allowed to speak on behalf of Keep Cumbrian Coal in the Hole.
Reasons to refuse this application include:
- Proximity to Sellafield
- Hydrology Impact
- Wildlife Impact
- Seabed Subsidence
- Methane Emissions
- Carbon Emissions
- Health Impacts
Proximity to Sellafield
A recent article in The Ecologist Magazine highlighted the proposed mine’s close proximity to this dangerous stockpile of plutonium. It stated:
“The potential for earth tremors and quakes resulting from mining is well known. Even if the tremors were small that is too big a risk to take in the vicinity of Sellafield.”
High intensity and liquefaction phenomena like that experienced at Christchurch in New Zealand are usually associated only with relatively large magnitude earthquakes. An earthquake in 1865 in the northwest of England (Rampside) suggests that a sufficiently shallow small event can also produce liquefaction. The Ecologist reported that: “Especially serious are the ~20 large holding tanks at Sellafield containing thousands of litres of extremely radiotoxic fission products.”
Discussing these tanks, the previous management consortium, Nuclear Management Partners, stated in 2012: “There is a mass of very hazardous [nuclear] waste onsite in storage conditions that are extraordinarily vulnerable, and in facilities that are well past their designated life.” The National Audit Office (NAO) stated these tanks pose “significant risks to people and the environment”.
One official review published in The Lancet concluded that, at worst, an explosive release from the tanks could kill two million Britons and require the evacuation of an area reaching from Glasgow to Liverpool. This would negate Cumbria County Council’s strategic objective of avoiding adverse impacts from developments (Objective 2, Cumbria Minerals and Waste Local Plan 2.27).
West Cumbria’s domestic freshwater supplies are already stressed with the halting of abstraction from Ennerdale to protect the River Ehen (Sellafield will continue to abstract from the Ehen for cooling and processes).
People in West Cumbria have experienced problems with borehole water being added to their supply. The vast discharge of water required to dewater the old existing and newly opened mines would inevitably impact on West Cumbria’s fresh water supply: “The history of contamination of watercourses in the areas raises concerns for some local residents in relation to the impact of the development on the complex hydrology of the area.”
This flies in the face of NPPF and Cumbria County Council’s own Minerals and Waste Plan to have regard for public health provision (2.25).
- “We are particularly concerned in regard to the potential impact upon the wider marine and coastal environment of the discharge of water into the sea, which has been pumped from the flooded anhydrite mine.” National Trust
- “The application site is in proximity (Solway Firth 1.5km) to a European designated site (also commonly referred to as Natura 2000 sites), and therefore has the potential to affect its interest features.” Natural England
- “The impact of any level of subsidence upon the terrestrial or marine heritage assets and designated sites and landscapes could be significant and permanent, therefore having a detrimental impact ..The history of contamination of watercourses in the areas raises concerns for some local residents in relation to the impact of the development on the complex hydrology of the area.” Colourful Coast Partnership
- Our position is to object to the proposed development on the grounds of the adverse impact on groundwater, surface water and biodiversity.”Environment Agency
- St Bees “supports England’s only breeding black guillemot – which are small in number and already vulnerable to stochastic events…The development has the potential to have an adverse effect upon the St Bees Head SSSI through disturbance to breeding birds during excavations and coal processing.” RSPB
It is clear from objections by the Colourful Coast Partnership and those quoted above (this is just a selection, there are many more) that biodiversity would be adversely impacted on by this development. This runs counter to NPPF policies and Cumbria County Councils own Minerals and Waste Local Plan (2.25)
As previously noted, seabed subsidence is an issue that would have environmental consequences anywhere. Close to Sellafield, the environmental consequences of seabed subsidence have far wider implications. This includes the possible resuspension of many decades worth of radionuclides that are currently on the Irish Seabed as a result of Sellafield reprocessing. Long-lived radionuclides (like plutonium or americium 241 nuclides) are still accumulating in the mud at the bottom’ of the Irish Sea.
Events like storm surges or seabed subsidence churn this up. Resuspended particles make their way to the beaches of Cumbria and beyond. This is intolerable and is already an issue for beaches in West Cumbria with radioactive particles being routinely found by the industry’s own beach monitoring system (which stops in the school holidays).
Knowingly creating the conditions for seabed subsidence from undersea coal mining runs counter to Cumbria County Council’s own policy of “risk reduction” regarding radioactive wastes. The Irish Sea Bed should be treated with care as it acts as a saucer-like container for the many decades worth of radioactive wastes which are best left undisturbed.
The fossil fuel industry’s methane emissions are far higher than previously thought. The famous landmark “candlestick” in Whitehaven is an air vent for the “most fiery pit in the kingdom.” Fiery, because this area is methane-rich. Last year the applicants West Cumbria Mining accidentally hit a methane seam off St Bees and just five miles from Sellafield while carrying out exploratory drilling. “Local authorities, fire rescue, police and the Environment Agency were all informed.” An explosion was averted this time. Cumbria County Council have a duty of care to make sure there is no next time.
Cumbria County Council is the custodian of hundreds of millions of tonnes of CO2 currently safety bound up in this coal under the Irish Sea. The developers are pushing the “need” to mine this coal for steel making. Why? There is a race on to develop ever more processes of steel making which do not involve the burning of fossil fuels. Sweden seems to be at the forefront of this.
Worldwide, the steel industry is well aware of the need to rapidly decarbonise. This is already happening with ever more steel recycling. For new steel production there are ultra-low carbon methods of steelmaking in development and soon to be deployed whether this is based on biomass, hydrogen or electrolysis.
This is happening now with some of the world’s largest iron ore producers (Brazil, China) also having the greatest potential for and commitment to renewable energy. There is no case for opening a new coal mine in Cumbria. Cumbria County Council will have a case to answer should they facilitate the opening of this the first deep coal mine in the UK for 30 years.
The old Marchon Chemical plant and anhydrite mine that fed it feature in the WCM application. We note that the anhydrite mine would need to be dewatered. This would be reckless given that previous operations are still having a “significant” impact.
“There is also a significant radiological impact due to the legacy of past discharges of radionuclides from non-nuclear industrial activity that also occurs naturally in the environment. This includes radionuclides discharged from the former phosphate processing plant at Whitehaven, and so monitoring is carried out near this site.”
This direct assault on health is additional to well-documented climate change health impacts and the intolerable danger that this mine would represent to the safe stewardship of Sellafield
We urge Cumbria County Council to turn down this application, which presents a danger to us all on many different levels.
On behalf of Keep Cumbrian Coal in the Hole
A Radiation Free Lakeland campaign
Petition to Keep Cumbrian Coal in the Hole