Mission Creep page 4

We asked a number of Freedom of Information questions on the 20th December 2021 which have not been answered directly or honestly with a simple yes or no but with replies serving to deflect and frustrate any scrutiny. Have the public been consulted about the RWM/NDA/CoRWM plan for Near Surface Disposal of Intermediate Level Waste at Drigg’s Low Level Waste Repository? The honest answer would be NO Has the Borough or County Council held a debate or vote on whether to take any steps towards Near Surface Disposal of Intermediate Level Wastes by alllowing 16 rock characterisation boreholes to be drilled at a depth of 120m into the underlying sandstone ? The honest answer would be NO What are the category of low and intermediate level wastes proposed for NSD and would this include the category of wastes previously designated by NIREX for a GDF ? The honest answer would be: the major components of Intermediate Level Wastes are nuclear reactor components, graphite from reactor cores and sludges from the treatment of radioactive liquid effluents. All of these wastes were previously designated by NIREX for a Geological Disposal Facility. Low Level Waste Repository's replies below:

NEAR SURFACE DISPOSAL of INTERMEDIATE LEVEL WASTES at DRIGG ?

The NIREX dump entrance proposal for Intermediate Level Wastes was rejected in the 1990s because the nuclear industry had no idea how much and how fast the planned dump would leak. They still have no idea. Furthermore for a shallow dump the leaks would be even faster. In a letter to “The Guardian” of June 28, ’07 the NIREX Inquiry Inspector had stated : “The relevant geology in west Cumbria is apparently now claimed to be ‘stable, although imperfect’ .…the imperfection consists of simply failing to meet the internationally agreed criteria on the suitability of rocks for nuclear waste deposit. The site should be in a region of low groundwater flow, and the geology should be readily characterisable and predictable, whereas the rocks there are actually of a complex volcanic nature, with significant faulting. Also, the industry was relying on an overlying layer of sedimentary strata to dilute and disperse any groundwater leakage, when the international criteria require such a layer to act instead as a barrier…The site is not suitable and investigations should be moved elsewhere… ” . And: “The site selection process was flawed, not treating safety as the most important factor, and irrationally affected by a strong desire to locate close to Sellafield.

Despite this inconvenient truth about West Cumbrian geology, investigations at Drigg are being carried out right now for the dumping of Intermediate Level Wastes in Near Surface Disposal

The Nuclear Decommissioning Authority have stated that:

"it is appropriate to investigate alternative options to a GDF for some of the inventory where there could be the potential to improve the overall management of Highly Active Waste. The NDA has carried out an initial technical study to investigate the feasibility of near-surface facilities for the disposal of some ILW in England and Wales, for example: certain decommissioning wastes"

West Cumbria Mining’s CEO Mark Kirkbride was appointed in 2019 to the Committee on Radioactive Waste Management who advise government on the UK government’s nuclear waste divestment options. Mark Kirkbride compiled CoRWMs Annual Report No 3724 which details the push for Near Surface Disposal "advice in the last year have been in relation to the concept of Near Surface Disposal (NSD) for intermediate level waste which is being explored by NDA as a potential solution for the disposal of specific intermediate level waste materials, reducing the volume of certain elements of the inventory into a GDF.

In March 2021 LLWR said in their “On the Level” newsletter: "There are two main concepts being considered for NSD in the UK: at surface level and at depth, 10s of metres below the surface. Data from 400 points in and around the Repository has been collected to support

feasibility studies to inform potential Near Surface Disposal (NSD) options in the future. The geophysics monitoring work to image the subsurface will help decide the best location for a potential NSD facility and inform the design optimisation process. NDA is exploring the benefits of developing NSD for disposing of a proportion of Intermediate Level Waste (ILW), but no decision has been taken on whether UK Government will pursue this option or whether LLWR, will in time, host a NSD facility. Optioneering studies are required to understand what’s possible on the site before any decision is taken on how to proceed. An NSD facility could bring benefits to the estate, for example by freeing up space in Sellafield’s Intermediate Level Waste stores, which could then be used for high hazard waste. The latest phase of the work sees the deployment of multiple wireless geophones along roadsides and the use of a specialist vehicle to generate vibrations into the ground,

In June 2021 the LLWR reported in their newsletter sent out to local people that: "Ground has been broken on the third of 16 boreholes designed to provide additional data on the geology and hydrogeology of the Repository to inform NDA decisions over future options for the site. Boreholes will reach a depth of 120m into the underlying sandstone and the work is expected to continue until October. The LLWR study is part of wider exploratory work being conducted by NDA into near-surface disposal (NSD) options as a possible alternative for some of the less hazardous solid higher activity wastes currently intended for disposal in a Geological Disposal Facility. This type of waste could potentially be safely and permanently disposed of in near-surface facilities, comparable to those surface facilities already in place at the LLWR site, or at slightly increased depths, up to a few tens of metres. This type of waste is safely disposed in this way in other countries. LLWR’s study is expected to conclude in 2023, when it will be submitted to NDA for consideration. No decision has yet been made on whether to proceed with NSD and a decision to go ahead would require an update to current Government policy, which would be subject to a comprehensive consultation process. It would also be subject to the relevant planning, permitting and other licensing processes – all of which include stakeholder engagement.

Local people and Councillors were not asked what they thought about this new “vision” for Drigg. Exploratory borehole investigation work has been done under "permitted development" despite the new boreholes being over 10 times deeper than 16 “offsite” boreholes drilled in 2004 which did require planning permission.

In 2004 two planning applications were submitted to Cumbria County Council for 16 boreholes on land in the vicinity of the Low Level Waste Repository near Drigg. Application 4/04/9008 was for thirteen boreholes on land to the north and northwest of the site. Application 4/04/9009 was for three boreholes to the west of the site, within or immediately adjacent to the Drigg Coast SSSI and candidate Special Area of Conservation. The primary purpose of the boreholes was to provide hydrogeological data about water table levels and to sample the water and soils to "confirm the absence of contamination. ” We are investigating whether these 16 boreholes of