28/1/13 CORE letter to Cumbria County Council Leader & Cabinet on nuclear waste process
[ 28 January 2013]
We write to you in your capacity as Leader of Cumbria County Council (CCC) and in relation to the impending decision by your Cabinet whether or not the County should proceed to Stage 4 of the Government’s MRWS programme. We raise the following points with you and ask that you and your Cabinet, as an MRWS Decision Making Body, afford them the fullest consideration in coming to a decision.
We accept that the Council must also consider an extensive range of issues thrown up by the work of the West Cumbria MRWS Partnership – including the high level of opposition from parish councils and others to moving to Stage 4, and the more recent strong concerns raised by other local organisations such as the National Park Authority, the Cumbria Tourist Board and the Friends of the Lake District.. Whilst these concerns may well dominate your Cabinet’s deliberations and indeed are likely to feature as major topics in the County Council elections later this year, we nevertheless believe the points we raise below have an equal relevance to your decision making.
Your letter of 1st October 2012 to DECC informs Baroness Verma that the County feels that ‘alternative radioactive waste management solutions should be considered in parallel with the MRWS programme, in case that process ultimately fails to secure a positive outcome’.
The County Council will be aware that CORE and other NGO’s (who oppose the underground disposal of higher activity nuclear wastes) declined several invitations to participate in the West Cumbria MRWS Partnership because alternatives were not to be discussed If it is now your Council’s intention to pursue such alternatives for the prudent reasons suggested to Baroness Verma, we contend it would be unsafe and indeed illogical for the Council to decide to move to Stage 4 until the use of alternatives has been pursued to a satisfactory conclusion.
For your information, CORE has consistently advocated the disposal of nuclear wastes in above-ground custom-built stores at the site of origin. This has the specific and quantifiable benefits of disposal sites being self-selecting rather than being reliant on volunteer communities, of placing responsibility where it belongs – on the nuclear industry, and of reducing the cross-country transport of nuclear wastes to the barest minimum. As such, this formed the basis of CORE’s evidence to the NIREX Inquiry of 1995/96.
Many of your County Councillors will recall the very robust stance taken by the Council at that Public Inquiry into the proposed Rock Characterisation Facility (RCF). The stance, widely supported by the general public, highlighted the issues of (i) the absence of alternative sites; (ii) the need for a site to show ‘good promise’ and (iii) the dangers of pursuing a process to a point from which ‘there is no return’. Whilst these issues were raised against the specific backdrop of the proposed RCF at Longlands Farm, Gosforth, they retain a generic value equally applicable to today’s MRWS situation
In evidence to the NIREX RCF Inquiry, CCC repeatedly brought to the Inquiry’s attention the Government’s recognition ‘that there must be consideration of alternative sites ……’.
That West Cumbria today officially represents the only area of the UK earmarked for potential investigation (on the sole basis of expressions of interest from local authorities and not on any form of geological merit) has turned what was, at the outset, a national MRWS programme into a local process for Cumbria despite the evidence of superior areas/sites existing elsewhere in the UK. We believe that, in recognising the weakness of a system that puts volunteerism before geological suitability, the County Council has a duty to declare its dissatisfaction with the current status and accordingly decide against moving to Stage 4 whilst the national imbalance remains.
The need to show good promise
CCC raised with the inquiry ‘whether there are good prospects of making a safety case’ and that, in geological terms, the site should be ruled out ‘given the likely availability of alternatives offering significantly lower potentials of risk and more readily determinable geologies’. Such a view is clearly relevant today given the strength of evidence – both within and outside the findings of the MRWS Partnership) – showing the ‘poor prospect’ of finding suitable geology and, by definition, the attendant difficulties of making a safety case for any West Cumbrian site.
On this basis, and with safety as the guiding principle, any decision by the County Council to move to Stage 4 would not only be wholly unsafe but also lead inevitably to the costly and time-consuming investigation of sites which, affording inferior geology to other UK sites and, by implication, higher potential risks, face eventual disqualification and rejection.
Pursuing a process to a point from which ‘there is no return’
Given the uncertainties that currently surround the prospect of the legal underpinning of the right of withdrawal from the MRWS process, the County Council must address public concerns of the very real risk in moving to Stage 4 of launching the County down a cul-de-sac of no return. For once work on selected West Cumbrian sites has started – and in the continuing absence of expressions of interest from other UK local authorities – the urgent needs of a Government-supported nuclear industry to dispose of its wastes will rule the day, outweighing any local authority and public opposition to the subsequent investigation and selection of sites which, for expediency, will be made to fit the bill.
By taking the decision now not to move to Stage 4, the Council will pre-empt the prospect of such an intractable situation arising and, at the same time, demonstrate to Cumbrian communities that their County Council has acted on their concerns and in their long-term interests.
You may recall that in 2008, in response to your Council’s invitation to comment on whether or not the Council should ‘express an interest’, we commented that it was neither in the public nor the Council’s interest to pursue an MRWS programme designed specifically to locate, investigate and progress an underground dump site within the County’s borders. With foreign wastes requiring disposal, an international facility covering an area of some 25 square kilometres underground would be detrimental to West Cumbria’s future prosperity, undermine plans to diversify the local economy and add to the nuclear blight already evident in West Cumbria.
The subsequent work of the West Cumbria MRWS Partnership and its final report have revealed, in CORE’s view, no evidence that would overturn or modify the view we took in 2008. To initiate the widely accepted need for diversification, the County Council must now withdraw from any further involvement in the MRWS process.
We have no doubt that Cabinet members will be only too aware that some 50 years of both overt and covert searching by successive Governments and the nuclear industry has failed to produce a nuclear waste disposal site – at the same time engendering deep mistrust among the general public. We contend that such mistrust will be exacerbated by a Council decision to move to Stage 4 of the current process, particularly as the focus will be on areas within the County that not only hosts geology of questionable potential but also local communities that are increasingly hostile. The likely failure to secure the tandem MRWS requirement of suitable geology and a willing host community will simply extend half a century of failure by a further few decades.
In summary we reiterate that, in placing volunteerism ahead of geological potential, the current MRWS process has isolated West Cumbria from the rest of the UK as a site for further investigation. This has resulted in localising what, at the outset, was heralded by Government as a national process to deal with a national problem. A vote by the County Council against move to Stage 4 of the faulted MRWS process would redress this national imbalance and, in so doing, create ‘a level playing field’ in which the investigation of superior geological potential elsewhere in the UK must be the driver of any future programme.
Finally, we believe there exists sufficient expertise within your Cabinet to see through the claims that a decision to move to Stage 4 is necessary as ‘the whole of our (West Cumbria’s) economic future depends on this’ and ‘if there is no waste depository in Cumbria, there will no new-build in Cumbria’ The evidence to support such claims exists neither in the final report of the West Cumbria MRWS Partnership nor elsewhere in the public domain. We trust therefore that the Cabinet will concentrate its deliberations on the established facts and not on such unsubstantiated and vested interest threats.
Martin Forwood. CORE Campaign Coordinator.