Memorandum submitted by Radiation Free Lakeland

(NPS 40)


Radiation Free Lakeland was formed in November 2008 following Cumbria County Council's "expression of interest" in the geological disposal of nuclear waste. Supporters are people from all walks of life in Cumbria and further afield whose aims are: a) to ensure the risks from nuclear waste are minimized and b) that no more nuclear waste is produced.


The DECC exhibition and presentation which precedes the 'Site Consultation' public discussions reiterate deliberately misleading statements. These statements include assertions that nuclear power is:


∑ Carbon free /Climate friendly


∑ Safe for the Environment


∑ Safe for human health


∑ Economic


∑ Sustainable


∑ Home grown




1. Carbon Free/Climate Friendly.....?

1.1 Every nuclear power plant requires a dedicated back up of energy - in fact they need an 'over supply' of energy to prevent catastrophe during operation and waste management. In the case of Sellafield's waste management the Fellside CHP plant does this job. Following a Freedom of Information request it was revealed that the amount of gas bought in to ensure "security of supply" to Sellafield last year was £30 million (FOI NDA REPLY 9781940). Any gas left over is sold on to the National Grid. Sellafield stopped producing electricity in 2003. The CO2 emissions from Fellside since then are in excess of 3 million tonnes. When asked, the NDA could give no reply as to how a secure energy supply to new build would be met or how Sellafield's own energy requirement would be met post fossil fuel.


1.2 The Nuclear Fuel cycle produces greenhouse gases thousands of times more potent than carbon dioxide. Following a Freedom of Information request from Radiation Free Lakeland (FOI - NDA 10689349) it has come to light that Sellafield (no longer producing electricity) quadrupled its emissions of hydrofluorocarbons (HFCs) from the period 2007 to 2008. HFC's are hundreds and can be thousands of times more powerful than carbon dioxide. The reporting threshold is 100kg but Sellafield produced over 4 times this amount in 2008 alone.


1.3 Apart from hydrofluorocarbons and other potent greenhouse gas emissions, the nuclear cycle absolutely relies on the production of chemicals such as concentrated nitric acid in large quantities. Nitrous oxide (N2O) is produced by nitric acid production and is not only 310 times more powerful than CO2 but it lasts over 100 years in the troposphere. According to the Nuclear Decommissioning Authority, Sellafield is home to the most dangerous concoction of tens of millions of gallons of nitric acid (1086.7 m3) in High Level Liquid Waste tanks holding "nitric acid solution containing fission products, some actinides and some solids". Fossil fuel and the internal combustion engine has done much to trash the environment but fossil fuel is well and truly trumped by nuclear power at the top of the polluting industrial food chain and reliant on all other polluters for its existence.




2. Safe for the Environment ....?

2.1 Following Freedom of Information requests from Radiation Free Lakeland the Nuclear Decommission Authority have revealed that:

"The Abstraction license issued by the Environment Agency to the NDA allows abstraction of a total of 6,637,307 M3 of water per annum, but the maximum abstraction in any 24 hour period must not exceed 18,184m3"

This equates to over 4 million gallons abstracted from Wastwater every day, essential to cool the nuclear waste (and provide nuclear workers and equipment with power showers etc ). More water is abstracted from the Calder and Ehen with discharges to these rivers. While the Lake District is known for its freshwater resources - this kind of relentless use and abuse is unsustainable especially when the resource is fresh water - the most precious and essential prerequisite for life. Wastwater was formed a relatively short time ago - 10,000 years - nuclear waste remains dangerously "hot" for substantially longer. When asked, the NDA could give no indication of how new build water supplies would be met. Seawater is too corrosive for many nuclear processes.


2.2 With regard to nuclear radiation and wildlife the nuclear guru James Lovelock has said, "If you wanted to preserve the biodiversity of rainforest, drop pockets of nuclear waste into it to keep the developers out. The lifespan of the wild things might be shortened a bit, but the animals wouldn't know, or care. Natural selection would take care of the mutations". For 'rainforest' substitute 'Cumbria.' James Lovelock's blasť prediction is backed up by evidence: "Hesse-Honegger discovered a shocking degree of deformation in bugs from fallout areas in Sweden. From 1986 until 2007, she systematically examined the morphological appearance of various types of true bugs around the world. She collected more than 16,000 Heteroptera, examined them in detail, identified different types of malformations and produced over 300 detailed illustrations. In areas around nuclear power plants and nuclear reprocessing facilities in Switzerland (Aargau), France (La Hague), and Germany (Gundremmingen), for example, severe disturbances and malformations were found in true bugs and other insects" Courtesy of Verlag Helvetica Chimica Acta (Chemistry & Biodiversity 2008, Vol. 5, issue 4, p. 499-539)


3. Safe for Human Health....?

3.1 The German company RWE is tendering for nuclear build here in Cumbria while effectively outlawed from new build in Germany largely as a result of health concerns In Germany. The German people object strongly to proposals to extend the life of existing plants - new build in Germany is off the agenda. This is chiefly as a result of the KIKK studies, showing a direct link between proximity to nuclear installations and cancer. As Dr Ian Fairlie reports in the New Scientist article 26th April 2008 "the KiKK studies (a German acronym for Childhood Cancer in the Vicinity of Nuclear Power Plants), whose results were published this year in the International Journal of Cancer (vol 122, p 721) and the European Journal of Cancer (vol 44, p 275). These found higher incidences of cancers and a stronger association with nuclear installations than all previous reports. The main findings were a 60 per cent increase in solid cancers and a 117 per cent increase in leukaemia among young children living near all 16 large German nuclear facilities between 1980 and 2003. The most striking finding was that those who developed cancer lived closer to nuclear power plants than randomly selected controls. Children living within 5 kilometres of the plants were more than twice as likely to contract cancer as those living further away, a finding that has been accepted by the German government".


3.2 The Radiation Linked Diseases Compensation Scheme based at Sellafield is there to compensate nuclear workers, but as the KIKK studies show the surrounding population up to 50k is also adversely affected by nuclear installations. While routine emissions are damaging to human health- the prospect of a serious accident would be catastrophic. In the same month that the Norwegians were told by the industry that a hypothetical 'accident' such as a loss of cooling water to the waste tanks 'could not happen' - the hypothetical accident became a reality. On April 1st 2009 there was a loss of cooling water to the High Level Waste tanks - the problem was hours away from being catastrophic. This loss of coolant to HLW tanks is designated as the 'Reference Accident' (worst credible accident) for Sellafield's Emergency Plans. The worst-case scenario would be public evacuation from Glasgow to Liverpool (perhaps permanent). The Norwegian report concluded that if just 1% of the tanks' inventory was accidentally released, the radioactive fallout in Norway would be five times greater in the areas worst affected by the Chernobyl accident. If 10% of the tanks' contents were released, the fallout would be fifty times the country's maximum post-Chernobyl experience.


4. Economic.....?

4.1 Others will speak of the tens of billions required for new build and the hundreds of billions required for decommissioning. Radiation Free Lakeland would like to highlight just some of the hidden economic costs of nuclear. For example a staggering £30M every year on gas to Sellafield. Sellafield has the obscene luxury of paying nothing - zilch - for its in excess of 4 million gallons of fresh water a day - around the same amount of water as three Cumbrian towns would use. In Cumbria, individual household water bills are rising year on year.

4.2 For the last ten years there has been an unprecedented increase in taxpayers money filtering through the Nuclear Decommissioning Authority to many essential services in Cumbria such as Citizens Advice, Schools and Hospitals. The NDA claims that its considerable largesse running into tens of millions is helping communities suffering from the economic shock of nuclear closure. With the sale of 'NDA' land (land acquired with public funds) for potential new build this largesse has instead become a 'slush fund' used with the rather abusive aim of grooming communities into passive acceptance of nuclear. For example, the NDA has released information, in response to a Freedom of Information request showing that £34m has been given to hospitals, colleges, and wildlife and heritage groups since 2005. Cumbria County Council has a staffer sponsored by the NDA, as does Made in Cumbria, established to help small businesses involved in the food and craft sectors.


4.3 Money has been given to a lifeboat appeal, footpaths, and a harbour wall scheme amongst other things. The Citizens Advice Bureau in Copeland has received almost £80,000. In addition to the £34m, the NDA will be "investing" £10m over three years in the University of Cumbria. According to The Guardian, the NDA is spending taxpayers' money on "social" projects "as if Christmas has come early".

Cumbrians are being "bought off" with their own money. Apart from the University of Cumbria, money is going to other organisations which should be properly funded by central government - Cumbria's nine cottage hospitals received £18m. Money the NDA and other nuclear companies are disbursing in Cumbria is going to organisations that Cumbrians are relying on to be impartial and vocal watchdogs on nuclear issues. Cumbria Wildlife Trust's work on the Biodiversity Action Plan was part funded by Sellafield Ltd. Friends of the Lake District and the Lake District National Park Authority both work in partnership with Cumbria Vision on various projects such as the Lake District World Heritage Project, and the Cumbrian Biodiversity Action Plan. Cumbria Vision is the main economic development agency in the County, and is promoting the West Cumbria Energy Coast Masterplan, which received £250,000 from the NDA.


5. Sustainable...?

5.1 The most widely accepted definition of sustainability can be traced to a 1987 UN conference. It defined sustainable developments as those that "meet present needs without compromising the ability of future generations to meet their needs"(WECD, 1987). The Golden Rule of Sustainability is "do unto future generations as you would have them do unto you". "Sustainable means using methods, systems and materials that won't deplete resources or harm natural cycles" (Rosenbaum, 1993).

5.2 With these principles of sustainability in mind the question should be posed:


Is nuclear power the biggest threat to Cumbria's future food security?


∑ Windscale Fire - Contaminated Lakeland Food - Systematically Destroyed


∑ Chernobyl - over 20 years ago -

353 British farms including in Cumbria are still under Restrictions


∑ Routine Emissions

"New evidence of an association between increased cancers and proximity to nuclear facilities raises difficult questions. Should pregnant women and young children be advised to move away from them? Should local residents eat vegetables from their gardens? And, crucially, shouldn't those governments around the world who are planning to build more reactors think again?"

2008 New Scientist - Dr Ian Fairlie -consultant on radiation in the environment



6. Home grown

6.1 New nuclear would "boost energy security."

Regarding "energy security," the known UK resource of uranium is on Orkney where the Orcadians successfully won a battle in the 1970's to keep their uranium in the ground. A direct consequence of nuclear fanaticism in Britain is having devastating effects worldwide. From the Grand Canyon to Lapland to Australia, indigenous communities around the world are fighting thousands of uranium mining claims.

Even if nuclear was everything that DECC falsely claim - that still would not justify new build in Cumbria or elsewhere in the UK. Energy needs can be met without the nuclear drain on resources.


7. Conclusions

7.1 People could be forgiven for assuming that the Department of Energy and Climate Change was created with the cynical remit to push for new nuclear build and 'geological disposal' at ANY cost - of health, safety, or trashing of the climate and environment. DECC have asked that people/organisations do not publish their responses to the draft Nuclear National Policy Statement until the select committee has 'appraised them' Is this to ensure that the Site Selection 'Consultations' - some of which have already taken place, can happen without the hindrance of dissenting voices being heard ? At the Site Selection 'Consultation' Meetings the DECC exhibition and officials are blandly reiterating all the nuclear fantasies contained in the draft (dodgy dossier) Nuclear National Policy Statement


7.2 Our response is NO - Radiation Free Lakeland opposes in the strongest possible terms the draft Nuclear National Policy Statement. Cumbrians should be assured of infrastructure such as schools and hospitals without being bribed into 'geological disposal' and new nuclear build in the vicinity of the worlds most ferociously radioactive stockpiles of nuclear waste. It seems that the process of 'consultation' is Decide, Announce and Defend the DECC's remit of promoting nuclear power .


January 2010