PRESS RELEASE 18.10.21
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EARTHQUAKE TRAFFIC LIGHT SYSTEM FOR COAL MINE NEAR SELLAFIELD?
(note: coal mining produces more and bigger earthquakes than the now banned fracking industry.)
Photo credit: David Autumns “The End of an Era”.
A new highly automated submarine coal mine planned for the Irish Sea off the Cumbria Coast “is likely” to cause earthquakes. In a worst case scenario this would affect the Sellafield nuclear waste site. Intensively radioactive holding ponds containing spent nuclear fuel and other high level wastes could rupture, releasing their contents into air, ground water and the Irish Sea.
This is one of the reasons nuclear safety group Radiation Free Lakeland are urging a Traffic Light System at least as stringent as that for fracking to be included in the Conditions being thrashed out now behind the now closed doors of the public inquiry.
Radiation Free Lakeland who did not have the resource to be a Rule 6 Party at the Coal Inquiry are urging all Parties involved in the Inquiry to push for a Traffic Light System as part of the Conditions that will be submitted to the Inspector no later than 29th October 2021.
RaFL say that the existing Conditions to be placed on the coal mine should the Secretary of State Michael Gove give his approval are “beyond generous” especially in respect of subsidence and seismic activity.
The additions made to the Conditions by Radiation Free Lakeland include:
“potential receptors which will be the subject of monitoring which should include the identification of vibration-sensitive and high hazard consequence onshore receptors in the region such as i) West Cumberland Hospital (2 miles) ii) South Egremont boreholes utilised for public drinking water (approx 4 miles) iii) Daily monitoring of seismic activity at Sellafield (five miles), “
“Risk will be mitigated through the implementation of a Traffic Light System where magnitudes of 0.3 and 0.4 are the amber level on the traffic light system and 0.5 is the red light at which operations must be halted.
Green light : A seismic event of magnitude less than 0.0 occurs during mining operations. Operations continue as normal. Daily reports are submitted to regulators ( Coal Authority, Office for Nuclear Regulation, Health & Safety Executive and Environment Agency)
Amber light: A seismic event between 0 and 0.5ML occurs during mining within the operational boundary (a specified geographical area). Operations continue with caution unless this coincides with a peak particle velocity of 1mm/s and then operations should halt.
Red light A seismic event of 0.5ML or greater occurs within the operational boundary or within the near region up to 5 miles. “
“No mineral working shall take place until a Traffic Light System is in place as referenced in advice to the Office for Nuclear Regulation by their expert Professor J Bommer (This paper was produced by Professor Julian Bommer of Imperial College London and was used to inform ONR’s response of 6 February 2019 to Radiation Free Lakeland https://www.onr.org.uk/foi/2019/201904001-3.pdf ). The Traffic Light System to be implemented shall be at least as stringent as that for fracking (as referenced by Professor J Bommer in advice to the ONR) with operations halted at 0.5ML. Note that the TLS would also apply to subsea mining.
Reason: To ensure that seismic activity events are monitored, investigated and mitigated in accordance with policy DC13 of the Cumbria Minerals and Waste Local Plan.”
“In the event that seismic activity which is attributable to onshore (or any subsequent subsea) mining activity at any of the receptors identified at condition 66 exceeds a Peak Particle Velocity (PPV) of 1mm/sec the operator shall halt operations and, carry out an immediate investigation into the reasons for that exceedance.” (note WCM have currently set themselves a generous ‘limit’ of 6mm/sec peak particle velocity – the same as for continous blasting – even at 1mm/sec ppv there will be complaints from local residents of ground vibrations.
Unlike fracking , West Cumbria Mining has enjoyed zero public scrutiny or outraged headlines regarding induced seismicity despite the mine’s location beneath the radioactively contaminated Irish Sea bed and the close proximity of the mine to Sellafield. In contrast to fracking, West Cumbria Mining would not be required to halt operations should induced earthquakes of 0.5 ML occur. Coal mining is known to induce earthquakes of 3 ML and more and the now effectively banned fracking bosses have previously drawn attention to this disparity : “It should be noted that the Traffic Light System required for hydraulic fracturing in the UK is significantly more stringent than the maximum ‘allowed’ induced seismic event for other hydrocarbon industries in the UK such as coal mining where magnitude >3.0ML events have been observed”. Cuadrilla Environmental Statement Appendix 1. Induced Seismicity May 2014 Preston New Road.
The volunteer nuclear safety group say “The seismic and subsidence impacts could release 75 years worth of radioactive wastes accumulated by the UK and much of the rest of the world now sitting at Sellafield and on the Irish Sea bed. There are over 140 tonnes of plutonium at Sellafield, the equivalent of 30,000 Nagasaki’s. The coal mine could yet be the catalyst to End All Eras, after all we are according to the Bulletin of the Atomic Scientists only 100 seconds to midnight. Unless.”
ENDS
References and Correspondence with the Public Inquiry regarding Conditions
“The majority of the anthropogenic related earthquakes were caused by coal mining and the decline in their numbers from the 1980s to the 2000s was concurrent with a decline in UK coal production.”
World’s riskiest nuclear waste site https://www.newscientist.com/article/mg22530053-800-shocking-state-of-worlds-riskiest-nuclear-waste-site/
Disparity with Fracking https://www.gov.uk/government/publications/traffic-light-monitoring-system-shale-gas-and-fracking
Fracking effectively banned https://www.edie.net/news/11/Fracking-ban-should-continue-for-UK-to-meet-net-zero–CCC-warns/
“It should be noted that the Traffic Light System required for hydraulic fracturing in the UK is significantly more stringent than the maximum ‘allowed’ induced seismic event for other hydrocarbon industries in the UK such as coal mining where magnitude >3.0ML events have been observed”. Cuadrilla Environmental Statement Appendix 1. Induced Seismicity May 2014 Preston New Road. https://consult.environment-agency.gov.uk/onshore-oil-and-gas/information-on-cuadrillas-preston-new-road-site/supporting_documents/ES%20full.pdf
EARTHQUAKES AND SELLAFIELD’S INFRASTRUCTURE: “Sellafield Ltd has modelled the consequences of a reasonably foreseeable seismic event for the site (a 0.25 g acceleration from an earthquake with a return period of once in 10,000 years), which could result in damage to a number of facilities and the release of radioactive materials.” says the Office for Nuclear Regulation in their report: Determination of the Off-site Emergency Planning and Public Information Areas for the Sellafield Nuclear Licensed Site: Radiation (Emergency Preparedness and Public Information) Regulations 2001 (https://www.onr.org.uk/pars/2014/sellafield-14-007.pdf ).
It is suggested that Sellafield’s infrastructure will withstand up to but not including a 9ML (equivalent to approximately 0.25g acceleration) earthquake. However buildings on the site such as the Magnox Silos (x 6) have unknown cracks in unknown silos already leaking radioactive liquor to the ground, this suggests that induced seismic damage in some infrastructure at Sellafield would occur at far lower magnitudes https://www.intechbrew.com/game-changers-storage-silo-challenge/
‐‐‐‐‐‐‐ Original Message ‐‐‐‐‐‐‐
On Tuesday, October 12th, 2021 at 11:59, Shearer, Erin wrote:
Dear Marianne
Thank you for your email detailed below.
Your comments on the conditions sections will be taken into account when the conditions are discussed again with the applicant and Rule 6 parties. If the conditions referred to below are updated at any stage, I will forward those updates to you for any further comments you wish to make. If the conditions referred to below remain unchanged, your comments will be added to the schedule of conditions which will cover the areas or agreement/disagreement and comments upon the same. This schedule will form part of the documents that will be submitted to the Inspector no later than 29 October 2021.
Kind regards
Erin Shearer
Senior Legal Officer
Cumbria County Council
From: Radiation Free Lakeland
Sent: 10 October 2021 19:20
To: Humphrey, Elizabeth Haggin, Paul
Subject: Radiation Free Lakeland Amendments to Conditions on Seismicity and Subsidence
Dear Liz Humphries and Paul Haggin
We are very grateful that the Inspector specifically asked for Radiation Free Lakeland’s comments on seismicity and that we be included in the loop about the ongoing conversation regarding these conditions. On subsidence – on thurs 30th September in the Inquiry conditions session , Samagita Moisha from RaFL asked directly for input into the subsidence conditions – so this is included below along with seismic conditions This all relates to Radiation Free Lakeland’s previous written and verbal submissions.
We would like to make it clear that should these amended conditions advised by Radiation Free Lakeland be actioned we would remain unequivocally opposed to Woodhouse Colliery.
With kind regards,
Marianne Birkby
Radiation Free Lakeland
RaFL amendments in red, below Introductory Note
Introductory Note to Conditions 66-71:
There is a basic issue to be overcome in that onshore conditions are the responsibility of Cumbria County Council’s Mineral Planning Authority and that marine conditions are the responsibility of the UK Government’s Marine Management Organisation (should the Secretary of State approve the development, the subsea area of the coal mine may not need an MMO licence). Onshore mining will have effects onshore and subsea mining will also have effects onshore. The Mineral Planning Authority of Cumbria County Council clearly has the responsibility to manage conditions for any onshore effects and harms resulting from Woodhouse Colliery whatever their source of origin onshore or subsea. Seismicity and subsidence which results in onshore harms in Cumbria is the responsibility of the Mineral Planning Authority to manage by way of monitoring. The subsea mining will impact onshore receptors, this should be acknowledged in conditions.
Reasons – It has been noted by marine pollution expert Tim Deere-Jones and others that subsea subsidence “could generate earthquake and liquefaction effects which may extend onshore as far as the Sellafield/Moorside sites.. any seabed subsidence in the WCM designated sub-sea mining zone would generate re-suspension of Cumbrian Mud Patch heavily radioactive seabed sediments. It is noted that such an event would generate elevated doses of man-made radioactivity to coastal zone populations and sea users along both the Cumbrian coast and at “downstream” regions further afield” and that there is “potential for such a radiological effect and the delivery of increased doses of radioactivity to relevant coastal zone communities, some of which have already been identified by the authorities as Coastal Critical Groups.”
Earthquakes and Sellafield’s Infrastructure: “Sellafield Ltd has modelled the consequences of a reasonably foreseeable seismic event for the site (a 0.25 g acceleration from an earthquake with a return period of once in 10,000 years), which could result in damage to a number of facilities and the release of radioactive materials.” In the Office for Nuclear Regulation report: Determination of the Off-site Emergency Planning and Public Information Areas for the Sellafield Nuclear Licensed Site: Radiation (Emergency Preparedness and Public Information) Regulations 2001 (https://www.onr.org.uk/pars/2014/sellafield-14-007.pdf ), it is suggested that Sellafield’s infrastructure will withstand up to but not including a 9ML (equivalent to approximately 0.25g acceleration) earthquake. However buildings on the site such as the Magnox Silos (x 6) have unknown cracks in unknown silos already leaking radioactive liquor to the ground, this suggests that seismic damage in some infrastructure at Sellafield would occur at far lower magnitudes.
CONDITIONS
66 Seismic Activity – Monitoring
1. No mineral working shall take place until a Seismic Activity Monitoring Scheme (SAMS) for onshore mining has been submitted to and approved in writing by the Mineral Planning Authority. The scheme shall include the following:
a) the methodology for monitoring all seismic activity. This shall identify the potential receptors which will be the subject of monitoring which should include the identification of vibration-sensitive and high hazard consequence onshore receptors in the region such as i) West Cumberland Hospital (2 miles) ii) South Egremont boreholes utilised for public drinking water (approx 4 miles) iii) Daily monitoring of seismic activity at Sellafield (five miles), and the equipment to be utilised for monitoring;
b) the location for the installation of the seismic monitoring array to effectively monitor the seismic activity impacts on the receptors identified at (a); and
c) the arrangements including timescales and frequency of reporting the outcome of monitoring to the Mineral Planning Authority, Reporting should be at least monthly ie 12 reports a year to the Mineral Planning Authority unless the peak particle velocity is is in excess of 1mm/s in which case the exceedence is reported immediately.
Once approved, the SAMS shall be fully implemented prior to the commencement of onshore coal mining and shall continue for a period of 6 years after the cessation of onshore coal mining. All monitoring and reporting shall be undertaken in accordance with the approved scheme.
No mineral working shall take place until a Traffic Light System is in place as referenced in advice to the Office for Nuclear Regulation by their expert Professor J Bommer (This paper was produced by Professor Julian Bommer of Imperial College London and was used to inform ONR’s response of 6 February 2019 to Radiation Free Lakeland https://www.onr.org.uk/foi/2019/201904001-3.pdf ). The Traffic Light System to be implemented shall be at least as stringent as that for fracking (as referenced by Professor J Bommer in advice to the ONR) with operations halted at 0.5ML. Note that the TLS would also apply to subsea mining.
Reason: To ensure that seismic activity events are monitored, investigated and mitigated in accordance with policy DC13 of the Cumbria Minerals and Waste Local Plan.
67 Seismic Activity – Investigation
In the event that seismic activity which is attributable to onshore (or any subsequent subsea) mining activity at any of the receptors identified at condition 66 exceeds a Peak Particle Velocity (PPV) of 1mm/sec the operator shall halt operations and, carry out an immediate investigation into the reasons for that exceedance. This investigation should be reviewed by an outside body and will confirm whether or not the seismic activity was induced by mining activity and, if so, identify the mining activities taking place, immediately prior to, the time the exceedance was detected.
The outcome of that investigation shall be set out in a report and submitted to the Mineral Planning Authority within 7 days of the exceedance for approval in writing by the Mineral Planning Authority. (Whether the MPA approves restarting operations; mitigation by change of mining practices or permanent cessation of works)
Reason: To ensure that seismic activity events are monitored, investigated and mitigated in accordance with policy DC13 of the Cumbria Minerals and Waste Local Plan.
68 Seismic Activity – Mitigation
Risk will be mitigated through the implementation of a Traffic Light System where magnitudes of 0.3 and 0.4 are the amber level on the traffic light system and 0.5 is the red light at which operations must be halted.
Green light : A seismic event of magnitude less than 0.0 occurs during mining operations. Operations continue as normal. Daily reports are submitted to regulators ( Coal Authority, Office for Nuclear Regulation, Health & Safety Executive and Environment Agency)
Amber light: A seismic event between 0 and 0.5ML occurs during mining within the operational boundary (a specified geographical area). Operations continue with caution unless this coincides with a peak particle velocity of 1mm/s and then operations should halt.
Red light A seismic event of 0.5ML or greater occurs within the operational boundary or within the near region up to 5 miles.
The following para would be largely superceded if the TLS is in place
Where a seismic activity investigation has been undertaken and reported to the Mineral Planning Authority under condition 67, and where the conclusion of that investigation is that the seismic activity was attributable to onshore mining operations, within 14 days of the receipt by the Mineral Planning Authority of the investigation report, mineral extraction shall cease and a scheme and programme for seismic activity mitigation shall be submitted to and approved in writing by the Mineral Planning Authority. The scheme shall:a)provide the rationale for the development of the mitigation measures with reference to the outcome of the investigation;b)detail the measures to be taken to reduce seismic activity; c)provide a programme for the implementation of the mitigation measures derived from the investigation report; and d)provide for an increase in the frequency of monitoring reporting (this should already be in place) to assess the efficacy of the mitigation measures which have been put in place.Once approved the scheme shall be implemented in accordance with the approved programme.
The developers West Cumbria Mining and the Mineral Planning Authority shall provide liability cover for all onshore impacts originating from subsea and onshore operations including radiological impacts from seismic events impacting on all receptors listed at 66a (this is not an exhaustive list). Liability cover is necessary for compensation to receptors including the already disadvantaged “Critical Coastal Groups” for seismically induced radiological damage.
Reason: To ensure that seismic activity events are monitored, investigated and mitigated in accordance with policy DC13 of the Cumbria Minerals and Waste LocalPlan.
69 Subsidence –
Monitoring
No working of minerals shall take place until a subsidence monitoring scheme has been submitted to and approved in writing by the Mineral Planning Authority. The monitoring scheme shall provide for monitoring the potential effects of subsidence on sensitive receptors. The scheme shall include the following: a)The methodology for subsidence monitoring including establishing the maximum zone of influence of onshore mining by projecting from the outward edge of extraction a line outwards and upwards from the relevant seam at 35o from a line perpendicular to that seam so as to intersect the surface, the methods for recording existing ground levels, method for monitoring changes in ground levels, equipment to be utilised and duration of monitoring following the cessation of onshore mining; b)The subsidence monitoring locations and the rationale for the number of monitoring points and the locations selected; c)The frequency of subsidence monitoring, and the rationale for the frequency selected; d)The arrangements for reporting the outcome of subsidence monitoring to the Mineral Planning Authority which routinely shall be no less than monthly; e)The method for the derivation of trigger subsidence levels at sensitive receptors which would represent a subsidence event; and f) Proposals for increasing the frequency of subsidence monitoring and for the reporting of that increased frequency of monitoring to the Mineral Planning Authority in the event that a subsidence event occurs.
A high hazard, high consequence sensitive receptor of subsidence is the Cumbrian Mud Patch above subsea mining operations. Subsea subsidence and consequent resuspension of seven decades of radioactive wastes will impact public health onshore up to 10 miles inland. Surface subsidence monitoring and reporting shall be undertaken in accordance with the approved monitoring and reporting scheme. Before subsea mining can proceed a 12 month period of daily radiation sampling and monitoring of beaches from Whitehaven to Drigg will be carried out with published findings to establish a baseline of existing radiological impact via the Cumbrian Mud Patch before subsea mining and likely subsidence proceeds.
In the event of a subsidence event under the Cumbrian Mud Patch, the developers and Mineral Planning Authority shall ensure onshore radiological monitoring of beaches are carried out. Timescales, methods and reporting for onshore beach monitoring regarding resuspension of radioactive wastes from the Cumbrian Mud Patch are to be approved.
Reason: To ensure that subsidence is monitored, investigated and mitigated in accordance with policy DC13 of the Cumbria Minerals and Waste Local Plan.
70 Subsidence – Investigation and reporting .
In the event that a subsidence event occurs, the zone of influence of the sensitive receptor shall be established by projecting downward and inward at an angle of 35o to the depth of seam being worked. Coal production within the zone of influence of the sensitive receptor shall be suspended until a subsidence investigation has been completed. The subsidence investigation shall determine the reason(s) for the subsidence event. The investigation shall review the mining activities taking place prior to the subsidence event being detected and determine which of these activities led to the subsidence event occurring. The findings of the investigation shall be set out in a subsidence investigation report which shall also identify the mitigation measures and a programme to be adopted to prevent a reoccurrence of a subsidence event. Where a subsidence investigation report has been concluded it shall be submitted to and approved in writing by the Mineral Planning Authority. Any mitigation measures shall be carried out in accordance with the Mineral Planning Authority’s written approval and the approved programme.
The developers West Cumbria Mining and the Mineral Planning Authority shall provide liability cover for all onshore impacts including radiological impacts from one or more subsea subsidence events impacting on the contaminated Cumbrian Mud Patch. Liability cover is necessary for compensation to receptors including the already disadvantaged “Critical Coastal Groups” for subsidence induced radiological damage. Reason: To ensure that subsidence is monitored, investigated and mitigated in accordance with policy DC13 of the Cumbria Minerals and Waste Local Plan.
71 Subsidence – Mitigation
Coal mining shall only recommence within the zone of influence of the sensitive receptor which was the subject of the subsidence event under condition 70 after the Mineral Planning Authority provide written notification to confirm approval of the investigation report and that the proposed mitigation measures are acceptable.
As noted in condition 70 mitigation measures should include compensation to “Critical Coastal Groups” exposed to increased radiation dose via the resuspended Cumbrian Mud Patch. Liability insurance should be in place to mitigate costs of remediation and compensation for onshore impacts of subsea mining.
Coal mining within the zone of influence of the sensitive receptor which was the subject of the subsidence event shall thereafter only take place in accordance with the mitigation measures approved within the subsidence investigation report.
Before subsea mining can proceed a 12 month period of daily radiation sampling and monitoring of beaches from Whitehaven to Drigg will be carried out with published findings to establish a baseline of existing radiological impact via the Cumbrian Mud Patch before subsea mining and expected subsidence proceeds. The developers West Cumbria Mining and the Mineral Planning Authority shall take full responsibility for compensation for injury to person and property to receptors impacted by the expected subsidence events. This will include onshore impacts such as radiological mitigation of impacted beaches. Reason: To ensure that subsidence is monitored, investigated and mitigated in accordance with policy DC13 of the Cumbria Minerals and Waste Local Plan.
Marine Management Organisation https://www.gov.uk/government/organisations/marine-management-organisation
Tim Deere-Jones – Briefing Paper on Subsidence and the Cumbrian Mud Patch
“Controls on anthropogenic radionuclide distribution in the Sellafield-impacted Eastern Irish Sea” Daisy Ray et al. https://www.sciencedirect.com/science/article/pii/S0048969720342893
Critical Coastal Groups impacted by Sellafield https://www.intechopen.com/chapters/68366
Magnox Silos leaking from unknown cracks at unknown places in the 6 silos https://www.gamechangers.technology/static/u/GC%20Challenge%20Statement%20-%20Leak%20Prevention%203.pdf
Keep Cumbrian Coal in the Hole 
Reblogged this on RADIATION FREE LAKELAND and commented:
Another Press Release out into the Silence on Earthquake inducing Coal Mine Near Sellafield –
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Reblogged this on Mining Awareness + .
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