LETTER TO THE UNITED NATIONS -MOORSIDE BOREHOLES -NO CONSULTATION

A LETTER TO THE UNITED NATIONS....
A Cumbrian Nuclear Safety Group Urge a United Nations
Investigation into Moorside. 

Moorside in the village of Beckermet is the site name given to  
proposed new nuclear build in Cumbria. Billed as "the biggest
nuclear development in Europe, " which happens to be
right next to the Sellafield reprocessing plant and
plutonium stockpiles.

Radiation Free Lakeland have written to the United Nations following the findings that the Hinkley new nuclear build underway in Somerset is in violation of the European Transboundary Environmental Impact Convention (Espoo Convention).

The Cumbrian group question the UN saying:  if Hinkley
is in breach of the Espoo Convention then surely
continued reprocessing at Sellafield and the
plan for new build is too?  Spokesperson Marianne Birkby
says: "the one thing we are told that you do not do with
a nuclear dump is disturb it, and yet that is exactly
what is happening now with Moorside boreholes on
land and offshore stirring up the decades old "legacy" of nuclear wastes
from Sellafield's reprocessing, it is not just our European neighbours in
the path of Sellafield's toxic 'legacy', the resuspended nuclear wastes 
will travel as far as the Arctic in just four years.
The full letter to the United Nations Economic and
Social Council below....

Radiation Free Lakeland are a volunteer group concerned with nuclear safety in Cumbria and we heartily welcome the United Nations use of the Espoo Convention which is a treaty about risks that come from pollution

crossing national boundaries (wind and water), and the right of neighbouring countries to have a democratic voice about trans-boundary pollution.

The key finding of the UN Economic and Social Council is
that Britain failed to notify neighbouring states and
the general public of the threat of trans-boundary
nuclear pollution from Hinkley Point C in the event of a
major accident.
We have to ask the following questions:  if Hinkley is
in breach of the Espoo Convention then surely continued
reprocessing at Sellafield and the plan for new build is
too?

Much of the nuclear waste discharged from Sellafield does as was intended and disperses out to neighbouring countries. Radioactive waste from Sellafield being well documented in the environment from Scotland to the Arctic. Incredibly Sellafield’s radioactive waste takes just 4 years to reach the Arctic. However, much of the waste from reprocessing neverreaches our European neighbours, instead it accumulates in our estuaries
and on the silts of the Irish Sea bed off Sellafield.

As the British Geological Survey have pointed out: “The
estuaries with their tidal dominance, are filling with
sediment from seawards with little landward input from
rivers.  They therefore remain a sink for Sellafield’s
particle- associated contaminants” So, a large
proportion of all the waste ever discharged from
Sellafield is sitting trapped within the silt and
clay of the Irish Sea bed.  The one thing that should
not be done with a nuclear dump is disturb it.  Let
sleeping dumps lie.
Is the plan for the biggest nuclear development in
Europe, next to Sellafield already in breach of the
Espoo convention?

Hundreds of boreholes are being drilled right now on land and sea directly in the shadow of Sellafield’s accidental and routine discharges. There has been no scrutiny or debate on this as new nuclear build is now a “Nationally Significant Infrastructure Project’ which means that the normal planning laws are waived. The onshore boreholes were rubber stamped by one delegated Copeland Council officer.

The “slightly radioactively contaminated’ ground water from the onshore boreholes on the Moorside site is being pumped to the River Ehen which then flows to the Irish sea. Higher up the river, farmers at Ennerdale are under strict restrictions as to how they can use the river and yet when it reaches the Moorside site, the Ehen is used as a radioactive sewer.

The drilling rigs have just moved into place in the Irish Sea off Sellafield for the offshore drilling and blasting. It was hard to find any point at which people could object but we found out late in the day that this offshore borehole drilling activity needed a license from the Marine Management Organisation.

Despite hundreds of letters, including a letter representing the thousands of people already opposing Moorside, NuGen were given the go ahead with drilling and inevitable resuspension of Sellafield’s nuclear wastes.

Who was consulted?

Not Cumbrian Councillors, the Cumbrian public, The Isle of Man, Scotland
nor Any European neighbours.

Please can you investigate this as The Biggest Nuclear Development in Europe appears to be going under the radar in every way.

Thank you

yours sincerely,

Marianne Birkby

on behalf of Radiation Free Lakeland

(address supplied)

References

Letter of Objection to the Marine Management Organisation / Moorside Boreholes –

Radiation Free Lakeland

https://mariannewildart.wordpress.com/2016/02/06/do-not- disturb-cumbrian-nuclear-dump/

http://www.theguardian.com/uk-news/2016/may/08/hinkley- point-united-nations-says-uk-failed-to-consult-over- risks

https://miningawareness.wordpress.com/2016/05/12/un- finds-the-uk-in-violation-of-transboundary- environmental-impact-convention-for-hinkley-point- nuclear-power-station-europe-at-risk/

11 thoughts on “LETTER TO THE UNITED NATIONS -MOORSIDE BOREHOLES -NO CONSULTATION

  1. Some more things supporting what you state:
    Around Half of the Radioactive iodine 129, half-life 15.7 million years, emitted by the nuclear facilities of Sellafield (UK) and La Hague (France), is estimated to end up in the Arctic. https://miningawareness.wordpress.com/2015/09/19/the-arctic-is-a-sink-for-radioactive-pollution-transported-from-far-away/ “98% of radioactive iodine in arctic sea ice may come from Europe” According to a March 2015 EU document: http://ec.europa.eu/environment/integration/research/newsalert/pdf/radioactive_iodine_in_arctic_sea_may_have_european_origin_407na7_en.pdf

    I think I have read that tritium makes it to the Norwegian coast, Baltic, Artic, very quickly, perhaps one to three months. The heavier elements move more slowly. .

    The NuGen “Moorside Development Environmental Impact Assessment Scoping Report“, May 2015, makes clear that they intend to EXCLUDE trans-boundary impacts, as well, if allowed:
    Regarding their emissions of radionuclides into the air they state: “6.7.5 Owing to the relatively modest scale of emissions to atmosphere, it is not considered that likely significant effects would arise within other Member States of the European Union, nor in other countries. On that basis, potential transboundary air quality effects arising from the Moorside Project have been scoped-out of the EIA.” (p. 109, emphasis added.) It will have impact, of course, especially in the event of an accident. The radionuclides don’t magically disappear.

    For emissions of radionuclides into the water they clearly exclude Ireland, Norway, and Scotland, all of whom are impacted by Sellafield radionuclide emissions and will definitely be impacted by Moorside Nuclear emissions: “7.5.3 For liquid discharges, the zone of influence for representative persons will be within the boundary of the local marine compartment, i.e. a water volume where the initial mixing of the discharge from the proposed power station into the marine environment is assumed to occur. For the Moorside Project the relevant local marine compartment has a coastal length of 20 km, a depth of 20 m and extends 5 km into the Irish Sea (Methodology for Assessing the Radiological Consequences of Routine Releases of Radionuclides to the Environment (European Commission 1995 and HPA-RPD-058 (Smith and Simmonds, 2009)). If the outfall extends beyond the local marine compartment (which is considered to be very unlikely at this stage) then other marine compartments offshore may also need to be included.” (p. 119)

    Norwegian salmon are of no consequence to them, of course. Nor are Scottish salmon. Here they contradict themselves, and it is clear that they must consult with neighboring countries, under the Espoo Convention: “Potential environmental effects that NuGen proposes to assess as part of the EIA … accidental pollution of watercourses, water bodies and/or the marine environment…;(p.460) (AMEC for NuGen NG-007.319, May 2015) https://miningawareness.wordpress.com/2015/06/29/uk-nuclear-transboundary-impact-case-pending-until-after-march-2016-espoo-convention-implementation-committee-expressed-profound-suspicion-of-non-compliance-by-the-uk/

  2. Pingback: LETTER TO THE UNITED NATIONS -MOORSIDE BOREHOLES -NO CONSULTATION | VeryVexed

  3. It turns out that there are actually two transboundary conventions, as I thought had recalled from reading BankWatch.org. The UN may have intentionally muddled them.

    Espoo seems to be to notify states but Aarhus seems to cover citizens of all countries. This means that the rights of British citizens are also violated under Aarhus from what I understand, and as you clearly stated in your letter. (It may be classified as a Human Rights violation too.) Sylvia Kotting-Uhl of the German Green Party states that she was complaining as a citizen under Aarhus and not as a parliamentarian on behalf of the German government.

    “The Aarhus Convention grants the public rights regarding access to information, public participation and access to justice, in governmental decision-making processes on matters concerning the local, national and transboundary environment. It focuses on interactions between the public and public authorities…
    The Aarhus Convention Compliance Committee was established to fulfill the requirement of Article 15 of the Convention on review of compliance to establish arrangements for reviewing compliance with the Convention.[23]
    The Convention has a unique Compliance Review Mechanism, which can be triggered in four ways:
    1. a Party makes a submission concerning its own compliance,
    2. a Party makes a submission concerning another Party’s compliance,
    3. the Convention Secretariat makes a referral to the Committee, or
    4. a member of the public makes a communication concerning the compliance of a Party.
    The Compliance mechanism is unique in international environmental law, as it allows members of the public to communicate concerns about a Party’s compliance directly to a committee of international legal experts empowered to examine the merits of the case (the Aarhus Convention Compliance Committee). Nonetheless, the Compliance Committee cannot issue binding decisions, but rather makes recommendations to the full Meeting of the Parties (MoP). However, in practise, as MoPs occur infrequently, Parties attempt to comply with the recommendations of the Compliance Committee. As of August 2009, 41 communication from the public – many originating with non-governmental organizations – and one submission from a Party had been lodged with the Convention’s Compliance Committee.[24]”
    https://en.wikipedia.org/wiki/Aarhus_Convention
    Sylvia Kotting-Uhl letter about Hinkley might also be used as a model by interested parties: http://kotting-uhl.de/site/wp-content/uploads/2013/03/2013-06-12_Sylvia_Kotting-Uhl_-Communication-to-the-Aarhus-Coventions-Compliance-Committee.pdf

  4. More information. Austrians and Germans have worked this out. I’m not sure if many others have. Some few in the UK have complained to UN on lack of public participation on road construction and so forth.

    This presentation on Austria underlines that Espoo is between states and Aarhus concerned public:
    “Espoo Convention and EU-directive 2003/35/EC request agreement of other state for consultations (Art 7 par 2 EIA-directive)
    – But Aarhus Convention not: it refers to the public concerned/and principle of non discrimination…
    Article 2 par 5 Aarhus Convention 5. “The public concerned” means the public affected or likely to be affected by, or having an interest in, (…)” including NGOs in any case
    Article 3 par 9 Aarhus Convention 9: (…) have access to justice in environmental matters without discrimination as to citizenship, nationality or domicile and, in the case of a legal person, without discrimination as to where it has its registered seat or an effective centre of its activities” https://www.umweltbundesamt.de/sites/default/files/medien/419/dokumente/country_report_austria_alge.pdf

    For complaining under Aarhus there is a special form: “Communications received by the secretariat prior to 17 May 2016 will be considered for preliminary admissibility at the 53rd meeting of the Committee (Geneva, 21-24 June 2016) so long as they are complete, in the required format and no translation is needed. Communications not considered for preliminary admissibility at the 53rd meeting may be considered for preliminary admissibility at the Committee’s 54th meeting in September 2016. The communications to be considered for preliminary admissibility at each meeting will be posted on this page no later than three weeks prior to the meeting. Communications not considered for preliminary admissibility at the 53rd meeting may be considered for preliminary admissibility at the Committee’s 54th meeting in September 2016.” Form: http://www.unece.org/fileadmin/DAM/env/pp/compliance/Format_for_communications_v13.02.2015.docx

    Texts of documents. Aarhus seems to include historical-nature preservation, including economic impacts of losses:
    http://www.unece.org/env/eia/about/eia_text.html
    http://www.unece.org/fileadmin/DAM/env/pp/documents/cep43e.pdf

  5. Pingback: Greens Urge Ireland to Insist on Hinkley Nuclear Power Consultation Following UNESC Ruling | Mining Awareness +

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