The following letter is to Cumbria County Council to oppose the planned incinerator at Kingmoor Park, Carlisle. Please send in your own letter of opposition and if you can get to the meeting in Kendal on 18th January to speak opposing or just show opposition that would be good! There is a facebook group for Carlisle Residents Against the Incinerator
By Email to : email@example.com
Proposed changes to Proposed Energy from Waste Incinerator at Kingmoor Park –
Planning reference 1/18/9012
Dear Development Control Committee.
On 18th January at 10am your committee may have a meeting to
decide whether or not to approve a section 73 amendment to the planned
energy from waste incinerator planned for Kingmoor Park in Carlisle. I would have liked to speak at this meeting to oppose the plan but I cannot make that date. I would be very grateful therefore if this letter could be given to the members of the development control committee ahead of the meeting.
In bringing the section 73 amendment it appears the company are trying to avoid
going through a full planning process again.
This is not a minor change to the plan as the developers are changing the type of incinerator originally proposed to a rolling grate incinerator, which by their own admission will be more polluting.
This will also mean more lorry movements and larger HGVs being used. The source of waste has been
changed to also include commercial and industrial, this is of particular concern.
Radiation Free Lakeland are a volunteer nuclear safety group with members throughout Cumbria.
We have already strongly opposed the Kingmoor Energy Recovery Facility Planning Application and would like to reiterate our opposition along with opposition to the section 73 amendment.
Our reasons include:
- This is near to housing estates and schools it will create environmental blight, noise, dust, pollution and adverse health impacts on the vulnerable.
- It is out of character of the area
- The developer has moved the already intolerable goalposts from Advanced Conversion Technology to a moving grate combustion incinerator and no recycling facility.
- Our most serious objections relate to nuclear decommissioning wastes. This is explained below.
This planning application and the Hespin Wood proposal 1/18/9006 do not include the type and origin of the waste.
Planners should be aware that once planning approval is given then the floodgates will be open to “exempt” and “free release” wastes from nuclear facilities. The public and the planners will not easily be able to stop this tsunami of waste from nuclear facilities which following the 2007 ruling is now entirely legal but is completely unethical and dangerous to public health, children are the most vulnerable. Cumbria County Council’s own Minerals and Waste Topic Paper acknowledges that: Substantial volumes of what were previously Very Low Level Wastes are not now regarded as radioactive wastes of any type. These are referred to as “out of scope” wastes. The thresholds have also been changed for wastes with slightly higher activity levels and which are still described as radioactive but which are “exempt” from the radioactive waste provisions of the Environmental Permitting Regulations”
It is this relaxation of the nuclear regime which is called “moving waste up the hierarchy” which led to the dumping of bags of radioactive wastes at Lillyhall amongst the “exempt” radioactive wastes. The only monitoring done is “reassurance monitoring” on the nuclear sites before free release.
- The UK Nuclear Industry have countless hundreds of thousands of tonnes of waste to “clear.” Their “Guide to Clearance and Exemption” boldly states that one of the mechanisms by which they plan to do this is by “♦ recycling or incineration (including recovery of energy from waste schemes).”
Until the public and our councils lobby and successfully change the 2007 act that allows the insanity of free release of “exempt” nuclear wastes to landfill and incineration, then planners must be aware that their decision could mean the transport and burning of potentially radioactive wastes which have only had a cursory “reassurance monitoring” before arrival at the incineration plant. The regulators and the nuclear industry can hide behind third party privateers and can deny this is happening, that the waste “is not radioactive”. This was our experience when we tried to blow the whistle on what was happening at Lillyhall in 2010. Sellafield was later prosecuted for illegally dumping three bags of low level and one bag of intermediate level waste into Lillyhall landfill amongst the already dangerous newly “exempt” nuclear wastes.
Privateers receive lucrative contracts to dump ‘free release” nuclear waste and clear the decks for new nuclear build, they are doing UK Government a massive service in getting shot of decommissioning wastes. Our questions were never answered as to why the operators of Lillyhall landfill were never prosecuted along with Sellafield.
It was the then new 2007 “exempt” classification led to Sellafield dumping three bags of low-level and one bag of intermediate level radioactive wastes into Lillyhall landfill. The judge who issued Sellafield with a fine acknowledged that this was potentially cancer causing and dangerous to health.
In 2010 While Sellafield was busy fly tipping bags of low and intermediate level waste into Lillyhall, Radiation Free Lakeland was pointing out again and again to Cumbrian councillors that this “exempt” novel pathway for dispersal of nuclear wastes would lead to “accidental” dumping of even higher activity wastes. The same applies to incineration and while this 2007 “exempt” ruling still exists, councils must be aware of the free pass for “exempt” radioactive wastes.
Radioactive wastes from the nuclear industry are already being sent for incineration as a recent letter from the Environment Agency (below) stated in regard to the radioactive metal recycling plant at Lillyhall: “Cyclife (could currently legally send the waste for incineration, but are not permitted to dispose of it to sewer and are storing around 2.5m3 of liquid waste on site. The incinerators which Cyclife may use (and use for other combustible waste) are Veolia at Ellsemere Port or Tradebe in Kent. ”
We urge you to refuse this application
On behalf of Radiation Free Lakeland
On 19 Dec 2018, at 10:06, CMBLNC Info Requests <Inforequests.firstname.lastname@example.org> wrote:
The subject of the permit variation is liquid waste generated by ingress of rainwater into containers and packages. Therefore where the documents refer to incineration, it is this waste that is being referred to. Cyclife have applied to the EA to permit this liquid waste, instead of going for incineration, to be disposed of to sewer. No liquid waste as yet been incinerated or disposed of to sewer. Cyclife could currently legally send the waste for incineration, but are not permitted to dispose of it to sewer and are storing around 2.5m3 of liquid waste on site. The incinerators which Cyclife may use (and use for other combustible waste) are Veolia at Ellsemere Port or Tradebe in Kent. Cyclife have stated that no liquid waste has been generated on site through the ingress of rainwater into packages for over 12 months since they made amendments to the vent port on the containers. Therefore they anticipate very low volumes, or indeed no, liquid waste to be generated going forward.
I hope this helps clarify matters.
Customer and Engagement Officer
Cumbria and Lancashire
Thank you for answers, we will look at this in detail.
First arising question is: exactly what is being incinerated and where?
Radiation Free Lakeland
CCC Minerals and Waste Topic Paper
UK Nuclear Guide to Clearance and Exemption
Radiation Free Lakeland warn Cumbria County Council about “exempt” radioactive wastes at Lillyhall
Cumbrian group Radiation Free Lakeland have sent a message to Lakeland Leaders including Cumbria County Council, The Bishop of Carlisle, Cumbria Tourism and LDNPA asking that they take two actions to ensure Cumbria has a viable future. The attached Map, “A Pictorial View of the Lakes Nuclear Sacrifice Zone?” will be hand delivered to the Leaders on 29th Sept 2010.
Action 1 – Stop Radioactive Wastes going into Landfill
Action 2 – Oppose the Geological Disposal of High Level Nuclear Wastes
Cumbria County Council and nuclear industry representatives are discussing how they can best accommodate the new deregulation of the nuclear industry which now allows nuclear waste into landfill. Lillyhall landfill in West Cumbria is already recieving nuclear waste from Chapel Cross nuclear plant in Scotland. The Cumbrian landfill operator has applied to take even higher level wastes. Keekle Head a former mine, quarry and near the source of the important River Keekle is earmarked to take similar dangerous wastes to those that are currently stored at Drigg.
A spokesperson for Radiation Free Lakeland said “instead of looking at how best to accommodate the new law which allows “exempt” nuclear waste into landfill – our leaders should be insisting that Chris Huhne reverses this law which runs counter to health and the environment. The nuclear industry is being dangerously deregulated.”
Nuke Landfill – Unexpected Doses Possible
This Summer the Government reported that even if radioactive wastes were
legally dumped in landfill, people still may be contaminated in ways that
hadn’t been thought of. This means that any claims that the future doses from Nuke Landfill have been carefully calculated – simply cannot be trusted.
Guidance (page 14) para 2.32 Draft Guidance on Exemptions Framework under the Radioactive Substances Act 1993 (Schedule 23 to the Environmental Permitting (England and Wales) Regulations 2011) 11th August 2010
If the dose from lower level radioactive wastes dumped in landfill cannot be trusted the resulting contamination from geological disposal of high level wastes could result in Cumbria’s permanent blight.
These two actions to :
Stop the dumping of nuclear waste in landfill and
Oppose geological disposal of high level wastes-
would ensure that Cumbria has the chance of a viable future.
All the compensation in the world is not enough ………
Fomento de Contrucciones y Contratas http://www.fccenvironment.co.uk/new-disposal-site-for-very-low-level-radioactive-waste-gets-the-go-ahead.html http://en.wikipedia.org/wiki/Fomento_de_Construcciones_y_Contratas
Radioactive Waste in a Landfill near You? http://www.indymedia.org.uk/en/regions/world/2010/04/448818.html
Nuclear Free Local Authorities – DECC Consultation: http://www.nuclearpolicy.info/docs/radwaste/Radioactive_Waste_Briefing_26_EA_RS_exemptions.pdf
2013 Sellafield Fined for Dumping Radioactive Waste in Landfill https://www.theguardian.com/environment/2013/jun/14/sellafield-fined-waste-landfill
- i) The failure was not isolated but systemic.
- ii) It potentially exposed those who handled waste off-site and the public to unnecessary risk.
- iii) It was not a first offence. A prohibition notice had been served on 28 June 2008, one year before installation of the new monitors, by the Department of Transport for breach of Regulation 5 of the 2009 Regulations. Sellafield Ltd had been fined twice for incidents involving the emission of radioactive material in 2005 and 2007 – £500,000 and £75,000 respectively.
Powerful Evidence to Pull the Plug on Radioactive Fly Tipping: https://mariannewildart.wordpress.com/2013/09/24/tim-farron-mp-powerful-evidence-to-pull-the-plug-on-radioactive-fly-tipping/