Planning Inquiry told Cumbria County Council were Misled on Fresh Water Usage and Impacts of Cumbria Coal Mine

Sellafield Outlying Planning Zone

Memorandum attached to our Evidence to the Public Inquiry. 

5/5/21  Memorandum from Radiation Free Lakeland

Applicant’s name:                                West Cumbria Mining Ltd

Call-in reference:                                  APP/H0900/V/21/3271069

BYERSTEAD FAULT

We would like to make it clear regarding the Byerstead Fault that County Councillors were, as far as we can see, not properly appraised of West Cumbria Mining’s profligate need for fresh water and what the likely impacts of such a huge, ongoing withdrawal of groundwater from the area would be.

We note that the developer’s “Project Description” predicts water usage at 261m3/h. Rather conveniently the water ‘available’( largely from the Byerstead Fault and newly mined voids) is stated as being 262 m3/h.   This is an enormous amount of water and would inevitably impact  groundwater and geology.   This was not discussed at all by councillors who were satisfied with the developer’s assurances that 98 m3/h of the water would be “recycled.”   We believe the councillors have been deliberately misled into believing that 98% of the total water would be recycled.

The water that West Cumbria Mining envisage obtaining due to ingress from the Byerstead Fault is 136m3/h.  This is far higher than the threshold above which an abstraction licence from the Environment Agency is required, and the Officers’ Report for 19 March 2019 notes at para.6.329 that “the removal of water from the mine would require an abstraction licence”.  The Environment Agency have told us there are no applications for abstraction.   There is no indication in Environmental Statement Ch.5 of how water will be obtained if the mines experience lower levels of water ingress than predicted (Public Supply?  Sharing Sellafield’s Supply?).

IMPACTS

Historically “Mine pumping in the Cumbrian Coalfield has abstracted up to about 20% of the reliable yield, dominating the flow pattern, and drawing in sea water to pollute the aquifers. Chemical analyses of mine drainage water reflect the infiltrated sea water, but suggest that normal groundwater is probably a sodium sulphate type with subordinate amounts of chloride. Mine workings in the Northumberland and Durham Coalfield were extensively interconnected and pumping maintained a water table at about 150 m below the ground surface. With the end of mining activity, groundwater levels are rising.”  http://earthwise.bgs.ac.uk/index.php/Hydrogeology_and_water_supply,_geology_and_man,_Northern_England

We note that the County Council’s Minerals and Waste Local Plan states:

1. 16.38  With respect to mineral applications, there is a requirement to establish the relationship that the development has with the water table. If the base of the excavation is near or below the anticipated water table, then there will be a requirement to establish an appropriate monitoring scheme. In some circumstances, the development may be considered unacceptable if it is carried out below the level of the water table.
2. 16.39  The current licensing exemption on dewatering is likely to be removed in 2017, subject to Ministerial approval, after which, dewatering activities will be brought into regulation by the Environment Agency.
   
   
   ENHANCED SEISMICITY DUE TO MINE DEWATERING
   “human activity – like water extraction – can cause the stress to be released quickly, rather than dissipating slowly over time. “It’s not just that you’re advancing an earthquake that would have happened anyway. It’s that you’re creating more or larger earthquakes,”  https://www.newscientist.com/article/dn22403-thirst-for-groundwater-caused-fatal-earthquake/#ixzz6tzBoSKIO
   Given the common knowledge that the activities of mining and dewatering can induce seismicity it is puzzling as to why Cumbria County Council have not demanded bullet proof evidence from the regulators that this mine would be safe.  This mine is not just anywhere it is 8km from Selalfield. A recent paper explains that the Sellafield site area is at high risk of liquefaction.   https://pygs.lyellcollection.org/content/62/2/116/tab-figures-data
   The lack of scrutiny on impacts is especially troubling as the County Council has a key role to play in the new regulatory requirements demanded by the Outlying Planning Zone of 50km from Sellafield  “Cumbria County Council has accepted the report at a meeting of the cabinet, which was chaired by Cllr Stewart Young. “It demonstrates the role of the county council in the nuclear industry,” he said. “This new concept of an Outlying Planning Zone is new. The zone is determined by kilometres from the centre of the Sellafield site. It takes you way beyond the boundaries of Copeland, showing that other areas of Cumbria would also be affected by a serious incident. “It includes BAE and the docks at Barrow. So, the implications of an accident are so significant for the whole county. It is a responsibility that sits then with Cumbria County Council as well as Barrow, Copeland and Allerdale. This is an important piece of work.”   https://www.in-cumbria.com/news/18753183.sellafield-nuclear-disaster-spread-across-cumbria—new-map-shows/   https://www.cumbria.gov.uk/elibrary/Content/Internet/533/561/44148123654.pdf
   We reiterate our request to the Planning Inquiry that Water and Nuclear Impacts are not only included but that they are central to the considerations of the Inquiry.  These issues are important (not just to Cumbria) and we feel strongly that they must not be smothered under the blanket of climate concern.
   yours sincerely
   Marianne Bennett (aka Birkby)
   on behalf of Radiation Free Lakeland