Responsibility for Discharged Radioactive Wastes on Cumbrian Mud Patch
Dear Sellafield Limited,
I asked the following question to Radioactive Waste Management and they have directed me to you and the Environment Agency.
Who is responsible for the decades of radioactive discharge on the "Cumbrian Mud Patch"
(...a large area of seabed, also known as the Irish Sea or Sellafield Mudpatch, associated with historic (and ongoing) discharges from the Sellafield site) ?
In the likely event of subsidence following mined out voids beneath the Cumbrian Mud Patch who would be accountable for the plutonium and other radioactive wastes which would be resuspended into the sea and returned to the coastal areas with the tides?
Would that responsibility for allowing the coal mine to induce subsidence of the Cumbrian Mud Patch and resulting resuspension of radioactive wastes lie with
Sellafield Ltd?
Environment Agency?
Office for Nuclear Regulation?
Nuclear Decommissioning Authority?
Not one of the above authorities has taken the initiative to safeguard the integrity of the Cumbrian/Sellafield Mud Patch by opposing the mining out of voids beneath the mud patch.
Just the opposite as the Mayor of Copeland has repeatedly claimed that Sellafield Ltd are actually supportive of a coal mine directly underneath the Cumbrian Mud Patch which is known to contain decades of radioactive discharge including plutonium wastes from Sellafield.
Yours faithfully,
Marianne Birkby
Case ref: 2020-0141
Dear Marianne,
Your request for information regarding the Cumbrian Mud Patch (Case ref: 2020-0141), was received on Wednesday 21 October 2020, and is being dealt with under the terms of the Environmental Information Regulations 2004.
Please note during the coronavirus (COVID-19) pandemic, we will endeavour to answer all requests for information within statutory time limits. However, there may be delays due to the effects of the pandemic, so please bear with us, we will answer your requests as soon as possible and try to keep you updated.
In some circumstances a fee may be payable and if that is the case, I will let you know the likely charges before proceeding.
Please do not hesitate to contact me with any queries you may have via [Sellafield request email]
Please remember to quote the reference number above in any future communications.
Kind regards
Janice
Corporate Affairs
Sellafield Ltd
"The information contained in this email may be commercially sensitive and/or legally privileged. It is intended solely for the person(s) to whom it is addressed. If you are not a named recipient, you are on notice of its status. Please notify the sender immediately by reply e-mail and then delete this message from your system. You must not disclose it to any other person, copy or distribute it or use it for any purpose.
Views expressed in this email are not necessarily those of Sellafield Ltd.
Sellafield Ltd, a Nuclear Decommissioning Authority company, is registered in England and Wales, Company number 01002607. The registered office is situated at Hinton House, Birchwood Park Avenue, Risley, Warrington, Cheshire, WA3 6GR."
This email has been classified as OFFICIAL
Case ref: 2020-0141
Dear Marianne,
Further to your request regarding the “Cumbrian Mud Patch” please see response below.
“ The level and distribution of radioactivity in the Environment is monitored and the results reported publicly . The information is provided in reports Radiation in Food and the Environment (RIFE), published by Government the most recent of which has been published on 5th November and covers the period up to 2019. Discharges from the Sellafield site have been made against the specific “ Authorisations “ from the very beginning of site operations in 1950’s to the present day. The current permit -Environmental Permitting (England and Wales) Regulations 2016. Radioactive Substance Activities Permit number - EPR/KP3690SX. V011 2020 came into effect on 1st October 2020. The data presented in RIFE for the area surrounding Sellafield also take clear account of the historic patterns of discharges and accumulations of materials. “
The potential effects on the Sellafield site from development of coal mining activities have been examined against the possibility of equivalent damage to facilities on-site e.g. via seismic effects, and both Sellafield and ONR conclude that effects from such sources on land are negligible. A very useful summary is available on the ONR website.
In the context of “voids” appearing due to mining methods , it is our understanding that the chosen method provides the necessary stability of the seabed above the mine, and therefore the creation of voidage is eliminated.
If you are unhappy with the way your request for information has been handled, you can request Sellafield Ltd carry out an internal review (contact: [Sellafield request email]).
If you remain dissatisfied with the handling of your request or complaint you have a right to appeal to the Information Commissioner at:
Information Commissioner’s Office,
Wycliffe House,
Water Lane,
Wilmslow,
Cheshire,
SK9 5AF.
Kind regards
Janice
Sellafield Ltd
"The information contained in this email may be commercially sensitive and/or legally privileged. It is intended solely for the person(s) to whom it is addressed. If you are not a named recipient, you are on notice of its status. Please notify the sender immediately by reply e-mail and then delete this message from your system. You must not disclose it to any other person, copy or distribute it or use it for any purpose.
Views expressed in this email are not necessarily those of Sellafield Ltd.
Sellafield Ltd, a Nuclear Decommissioning Authority company, is registered in England and Wales, Company number 01002607. The registered office is situated at Hinton House, Birchwood Park Avenue, Risley, Warrington, Cheshire, WA3 6GR."
Dear FOI Enquiries (SL),
You have not answered as to who is responsible for the accumulation of Sellafield's radioactive wastes (including 500kg of plutonium) on the sea bed above the coal mine in the area known in numerous scientific reports as The Cumbrian Mud Patch - or The Sellafield Mud Patch
The developers West Cumbria Mining do not say, as you suggest, that there would be no subsidence resulting from the planned undersea coal mine. They say that subsidence would be unavoidable which is why they propose backfilling 25% of the void onshore and in the Marine Conservation Zone area to try and mitigate against subsidence.
The remaining voids ie 75% of the mine would be at subsidence risk. This includes the area of the Cumbrian Mud Patch with radioactive wastes in the silts. Subsidence would cause resuspension of radioactive wastes into the water column as well as impacting on geological stresses..
We ask again - WHO IS RESPONSIBLE FOR THESE RADIOACTIVE WASTES ON THE SEA BED?
We are astounded that according to the Mayor of Copeland, Sellafield actually supports the coal mine, the public expect Sellafield to be reducing harm not inviting it with induced seismicity and subsidence.
From West Cumbria Mining's own documentation:
"4.2 OFFSHORE MINING METHOD
CUMBRIAN METALLURGICAL REVISED ENVIRONMENTAL STATEMENT COAL PROJECT NOVEMBER 2018
PROJECT DESCRIPTION
Coal will be predominantly mined off shore in areas known as panels (Figure 9). These panels will typically be some 110 m wide, and can in some cases be over 1 km long, depending on the geological conditions encountered. Up to 60 % of coal within
the boundaries of a mining panel may be extracted with 40 % being left behind. It is above these panels that subsidence is expected to occur. At present, the precise location of these panels is indicative and will only truly be established during the mining operation when a greater understanding of the structural geology is gained after accessing the particular area to be mined. None of these panels will be developed under the MCZ."
Yours sincerely,
Marianne Birkby
Case ref: 2020-0141
Dear Marianne,
With regard to the question “Who is responsible for these radioactive wastes on the seabed” We can only respond in respect of Sellafield Ltd. discharges. The information which is referenced in RIFE (Radioactivity in Food and the Environment) covers Sellafield along with other industry discharges to the Irish Sea.
From the commencement of nuclear operations at Sellafield, effluent discharges have been monitored, regulated and controlled in accordance with permitted levels and limits, and the impact on the marine environment understood. These have varied over time, in ways which are well documented on the public record. The results of sampling the environment continue to be reported both by Sellafield Ltd, and independently by regulatory agencies. The consequences arising from both current discharge practices and history, are evaluated and reported upon in the public domain, including the effects from historic practices undertaken within previous regimes of controls and limits. This maintains up to date, practical and public information on radioactivity in the environment.
Consideration of the potential for resuspension of deposited radioactivity on the seabed is included, in particular that associated with some forms of fishing practices, again this is an integral part of the public reporting. The most recent report on Radioactivity in Food and the Environment 2019: RIFE 25 can be found at; https://www.gov.uk/government/publicatio....
If you are unhappy with the way your request for information has been handled, you can request Sellafield Ltd carry out an internal review (contact: [Sellafield request email]).
If you remain dissatisfied with the handling of your request or complaint you have a right to appeal to the Information Commissioner at:
Information Commissioner’s Office,
Wycliffe House,
Water Lane,
Wilmslow,
Cheshire,
SK9 5AF.
Kind regards
Janice Amor
Sellafield Ltd
"The information contained in this email may be commercially sensitive and/or legally privileged. It is intended solely for the person(s) to whom it is addressed. If you are not a named recipient, you are on notice of its status. Please notify the sender immediately by reply e-mail and then delete this message from your system. You must not disclose it to any other person, copy or distribute it or use it for any purpose.
Views expressed in this email are not necessarily those of Sellafield Ltd.
Sellafield Ltd, a Nuclear Decommissioning Authority company, is registered in England and Wales, Company number 01002607. The registered office is situated at Hinton House, Birchwood Park Avenue, Risley, Warrington, Cheshire, WA3 6GR."
Dear Sellafield Limited,
Please pass this on to the person who conducts Freedom of Information reviews.
I am writing to request an internal review of Sellafield Limited's handling of my FOI request 'Responsibility for Discharged Radioactive Wastes on Cumbrian Mud Patch'.
The question of WHO IS RESPONSIBLE FOR THESE RADIOACTIVE WASTES ON THE SEA BED? has not been answered. Sellafield reply that they and other agencies are "Monitoring" the radioactive pollution. This "monitoring" is not a substitute for taking responsibility for and avoiding resuspension of decades of discharged radioactive wastes. Instead of working to avoid resuspension Sellafield is actively SUPPORTING the coal mine from which subsidence is "EXPECTED TO OCCUR". This means that resuspension of radioactive wastes is also "EXPECTED TO OCCUR". The public expect Sellafield and the nuclear industry to be taking full responsibility for their nuclear wastes by reducing harm not actively inviting it with support for a development which induces seismicity and subsidence. Our question of WHO IS RESPONSIBLE FOR THESE RADIOACTIVE WASTES ON THE IRISH SEA BED? has not been answered by Sellafield.
From West Cumbria Mining's own documentation:
"4.2 OFFSHORE MINING METHOD
CUMBRIAN METALLURGICAL REVISED ENVIRONMENTAL STATEMENT COAL PROJECT NOVEMBER 2018
PROJECT DESCRIPTION
Coal will be predominantly mined off shore in areas known as panels (Figure 9). These panels will typically be some 110 m wide, and can in some cases be over 1 km long, depending on the geological conditions encountered. Up to 60 % of coal within
the boundaries of a mining panel may be extracted with 40 % being left behind. It is above these panels that subsidence is expected to occur. At present, the precise location of these panels is indicative and will only truly be established during the mining operation when a greater understanding of the structural geology is gained after accessing the particular area to be mined. None of these panels will be developed under the MCZ."
Yours sincerely,
Marianne Birkby
A full history of my FOI request and all correspondence is available on the Internet at this address: https://www.whatdotheyknow.com/request/r...
Yours faithfully,
Marianne Birkby
Dear Marianne,
I have passed on your request regarding the handling of your freedom of information request to be reviewed.
The reviewer will be in touch soon.
Kind regards
Janice
Corporate Affairs
Sellafield Ltd
This email has been classified as OFFICIAL
Dear Ms Birkby
I can confirm that I have been asked to undertake an internal review of
this freedom of information request. I have commenced the review this
morning and I will get back to you with some feedback as soon as possible.
Thank you for your patience in this matter,
Kathryn McCloghrie
Head of Corporate Strategy
Sellafield Ltd
"The information contained in this email may be commercially sensitive
and/or legally privileged. It is intended solely for the person(s) to whom
it is addressed. If you are not a named recipient, you are on notice of
its status. Please notify the sender immediately by reply e-mail and then
delete this message from your system. You must not disclose it to any
other person, copy or distribute it or use it for any purpose.
Views expressed in this email are not necessarily those of Sellafield Ltd.
Sellafield Ltd, a Nuclear Decommissioning Authority company, is
registered in England and Wales, Company number 01002607. The registered
office is situated at Hinton House, Birchwood Park Avenue, Risley,
Warrington, Cheshire, WA3 6GR."
This email has been classified as OFFICIAL
Dear Ms Birkby
In connection with your request for an internal review of the above case I
write to inform you of the conclusion, key findings and learning from the
internal review.
Conclusion
The internal review concluded that the request handling procedure has been
properly followed and appropriate documentation was referenced.
Key findings
• Whilst the FoIA does provide the public access to information, it only
refers to ‘recorded’ information held electronically or in paper format.
Questions, requests for explanations, clarification, opinions etc. are
therefore not covered by this legislation unless they have been
documented. We therefore do not regard your request as a valid under the
legislation. Having said that in a positive attempt to address your
concern, we have carried out an internal review as stated above.
• The review has not identified any more information in relation to this
already held by Sellafield Ltd.
• The information requested does not exist in our corporate records and as
such is not something that we can disclose.
• Speculation or opinion in relation to legal liability is not an
appropriate form of ‘information’ to share and must be avoided.
Learning
Any learning points derived from the internal review will be fed back to
enable us to review and improve our processes.
If you remain dissatisfied with the handling of your request or complaint
you have a right to appeal to the Information Commissioner at:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Yours sincerely,
Tim Houghton
Head of the Conduct Compliance Office
Sellafield Ltd
eMail: [1][email address]
[2]cid:image001.jpg@01D686BF.3492CDC0
"The information contained in this email may be commercially sensitive
and/or legally privileged. It is intended solely for the person(s) to whom
it is addressed. If you are not a named recipient, you are on notice of
its status. Please notify the sender immediately by reply e-mail and then
delete this message from your system. You must not disclose it to any
other person, copy or distribute it or use it for any purpose.
Views expressed in this email are not necessarily those of Sellafield Ltd.
Sellafield Ltd, a Nuclear Decommissioning Authority company, is
registered in England and Wales, Company number 01002607. The registered
office is situated at Hinton House, Birchwood Park Avenue, Risley,
Warrington, Cheshire, WA3 6GR."
References
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