As representative of the first group opposing the coal mine I was phoned up by Radio 5 Live last night to expect a call this morn at 7.35am to talk on their breakfast show.
The researcher wanted to know what I would be highlighting – I said we had already lobbied to have a traffic light system for earthquakes (brushed aside by the Planning Inspector as part of the conditions on the coal mine) and we would now push hard for that as coal produces more earthquakes than fracking.
Unlike fracking there is no traffic light system in place to halt coal operations should earthquakes occur and that this is especially important as the coal mine is just a few miles from Sellafield.
Also that the coal boss is the government’s nuclear dump advisor appointed to the Committee on Radioactive Waste management in 2019 to deliver a Geological Disposal Facility. This should make the Govnts approval of the coal mine null and void ethically (cronyism) and possibly legally- anyway -needless to say they havn’t rung up but have gone with the ‘safe pair of hands’ of Friends of the Earth who keep to the safe narrative of climate, steel and jobs.
I was also going to say that the coal mine would produce 400,000 tonnes of CO2 a year – this pales to the nuclear waste industry’s 1,046,950 tonnes of carbon dioxide equivalent (CO2e) a year – from the NDA “Using Greenhouse Gas Protocol methodology, the total NDA group carbon footprint for 2019/20 is 1,046,950 tonnes of carbon dioxide equivalent (CO2e)” and the coal boss has been appointed to advise that industry!
The researcher said he didn’t know about all that and agreed it was scandalous – the BBC obviously still don’t want to expose the full truth about the coal mine which is great for our nuclear obsessed govnt..
Photo by Egor Kamelev on Pexels.comFulmar – photo by Dorothy Bennett
The following request has been sent to the Marine Management Organisation (MMO) in the light of West Cumbria Mining’s statement that they “might not need a licence from the MMO” should government approve the plan. Do they know something we don’t given the proximity to Sellafied, the radioactively contaminated Cumbrian Mud Patch (above the mine) and the ecologically sensitive marine protected area of the Irish Sea:
Dear Marine Management Organisation,
West Cumbria Mining have said that “we may not need a licence from the Marine Management Organisation” to mine for coal under the Irish Sea in an area of multiple conservation protections.
Has a pre-application submission been made by West Cumbria Mining for Woodhouse Colliery?
If this is the case I request sight of:
1. Pre-application submission/s from West Cumbria Mining 2. All Replies from the Marine Management Organisation to West Cumbria Mining
Why are the seismic and subsidence issues being ignored by NGOs and media? That is for them to answer. Whatever the reason the ongoing silence it is putting us all at immediate danger of an unlivable radioactively contaminated environment.
This is the latest in the extensive evidence on earthquakes caused by deep coal mining …
Different from the shallow coal seam, in deep mining, the dynamic response of overlying rock has changed significantly due to the high in-situ stresses and complex geological conditions. The frequent occurrence of strong mine earthquakes seriously restricts the safe and efficient mining of deep coal resources. This paper investigates the distribution and evolution of strong mining earthquakes during the process of deep coal seam mining in Dongtan coal mine of China by means of the microseismic monitoring and surface subsidence monitoring technologies. Results show that strong mine earthquakes occurring in the 1st square of the single goaf in each working face take the largest proportion. Most of the mine earthquakes are basically concentrated in the lower hard rock layer in the early mining stage. As the working face advances, mine earthquakes primarily rise straightly to the far-field hard layers. In the early stage of coal mining, the frequency of earthquakes is significantly high. After the mine earthquake goes into the higher hard strata, the frequency of strong mine earthquakes in lower layers decreases. The strong mine earthquake occurs with higher probability when the surface subsidence rate changes rapidly. When multiple layers of hard rock exist, the overburden fracture behaviors become complicated. A large energy mine earthquake in far-field overlying hard strata during deep coal mining is generally caused by the coordinated fracture of multi-strata, which can be reflected by the waveform of mine earthquakes.
Article highlights
The distribution and evolution of strong mine earthquakes during the process of deep coal seam mining are investigated.
As the working face advances, mine earthquakes primarily rise straightly from low field hard strata to the far field.
The strong mine earthquake wave characteristics and surface subsidence behaviors when the earthquake occurs are also investigated.
Not to mention the Subsidence and the Radioactive Mud Patch
This is our response to West Cumbria Mining and the Council’s agreement on conditions should the Secretary of State rubberstamp WCM’s coal mine.
We vehemently disagree with the conditions on seismicity and subsidence as agreed by WCM, the Rule 6 parties and Cumbria County Council. We ask for evidence of justification from WCM for the generous conditions on subsidence and seismicity. The very small concession to monitor all seismicity is meaningless when the limits set at which actions would be taken are generous and the outcome is not to halt operations but for WCM to merely deliver a report.
We are devastated to have been sent the report by (WCM) planning advisors, IC Planning, that: “The Rule 6 parties, Friends of the earth and SLACC, have both confirmed that they have no issuewith the subsidence and seismic activity condition as they are currently drafted. Both parties have provided extensive commentary on a wide range of other conditions and aspects of the proposals, but have not chosen to do so in relation to these specific conditions.” (Note: SLACC have contacted me saying they “do not agree” with the conditions on seismicity and subsidence – lets hope that disagreement from SLACC is voiced in the final conditions).
We agree with the former UK climate envoy John Ashton who has said: “It is morally incoherent” to focus on climate without looking at subsidence of the contaminated Irish Sea bed and induced seismic impacts on the Sellafield site. It will be interesting to see how this all plays out given that the coal boss Mark Kirkbride is employed by Government to advise on nuclear waste plans, his expertise is, after all, in digging very big holes https://www.lakesagainstnucleardump.com/post/government-take-advice-from-coal-mine-boss-over-deep-nuclear-dump-plans .
“WCM can approach these parties and request access to monitor using their electricity and wifi but cannot guarantee permission will be granted.”
RFL Response: WCM must be responsible for providing power and wifi for equipment used in seismic monitoring at high vibration- sensitive and high hazard consequence onshore receptors in the region such as i) West Cumberland Hospital ii) South Egremont boreholes utilised for public drinking water and Sellafield. The receptors should not be responsible for providing electricity and monitoring for WCM.
Unless seismic activity is taking the very long route by road, the shortest distance from the nearest point of the coal mine’s subsea area identified by WCM’s location maps is South Egremont under 4 miles and Sellafield, five miles. Unless WCM can prove otherwise their disingenous claims on distance between the nearest point of the subsea coal mine and the highly vulnerable receptors, should be struck out of official records.
Images – Distances from WCM’s mining interests to receptors, taken from the “as the crow flies” distance calculator http://www.tjpeiffer.com/crowflies.html and WCM’s location map with RaFL additions.
67 Seismic Activity – Investigation
WCM Response
“1mm/s threshold is unreasonable and impractical, – suggest retaining 6mm/s as per original condition.”
RFL Response
What evidence is there that the 1mm/s peak particle velocity threshold agreed by the Planning Inspector during RFL’s contribution to conditions is unreasonable and impractical?
WCM’s 6mm/s PPV is the threshold used for blasting and 1mm/s is the point at which residents will complain of vibrations.
WCM Response
“This is not a fracking project”
RFL Response
If this was a fracking project a stringent Traffic Light System would by legal requirement be put in place – as Cuadrilla have said: “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.
WCM Response
“Unreasonable to stop if cause not known. Outside body not defined.”
RFL Response
If the cause is not known operations should be halted until the cause is known. The “Outside body” refers to the appropriate regulatory authority.
68 Seismic Activity – Mitigation
WCM Response
“Suggest the WCM TLS =
C66 – continuous monitoring (Green)
C67 – investigation if PPV > 6mm/s (Amber)
C68 – mitigation if investigation demonstrates WCM at fault (Red) Although a case could be made from the references later to increase the threshold, WCM have not pursued this”
RFL Response – WCM TLS applies only to PPV not to Magnitude of earthquake
C66 – continous monitoring (GreenP
C67 – investigation if PPV > 1mm/s (Amber)
CC8 – halt to operations if investigation demonstrates WCM at fault (Red)
Magnitude TLS Green light a seismic event up to 0.0 occurs operations continue normally.
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.
69 Subsidence Monitoring
WCM Response
“Prawn fishing in the mud patch and weather conditions are more likely to have an influence.”
RFL Response
What evidence does WCM have that “prawn fishing” and “weather” are more likely to have an influence on resuspending radioactive silts from the Cumbrian Mud Patch than subsidence and climate impacts ?
We have searched for referenced academic research studies of the volume/mass of seabed sediment re-suspension following prawn trawling in, or near, the unique seabed fine sediment feature known as the Cumbrian Mud Patch. We have found no reference to any such studies.
We challenge WCM to provide the referenced academic research data on which they base their claim that sediment re-suspension generated by shrimp trawling and weather factors will generate a greater degree of sediment re-suspension than sub-seabed mining subsidence.
Unless WCM can produce copy of the relevant, fully referenced academic data we urge the Inquiry to regard the WCM statement/claim as spurious and un-substantiated, to disregard it, and to ensure that it is struck out of any record of official proceedings.
If WCM can produce copy of the relevant, fully referenced academic data, we request that the material be regarded as late submitted evidence and that we be granted an extension period in which we can review, consider and respond to this late submitted evidence. If such a time extension is not available or not permitted we formally request that the late submitted evidence be withdrawn and that any reference to the WCM claim be struck out of the record of of official proceedings.
We note that the North Western Inshore Fisheries and Conservation Authority provided an early submission to Cumbria County Council on Subsidence saying:
“impact on shoreline profile and wave heights. NWIFCA note that WCM propose a ‘no mine zone’ within Cumbria Coast MCZ and St Bees SSSI which we welcome. WCM state that “Given the small predicted seabed height changes, the slow rate of subsidence and the small changes in slope, combined with the fact that subsidence will not occur over the whole mined area it is likely that impacts on statutory protected areas in the vicinity of the development (i.e. the Cumbria Coast MCZ and the Solway Firth pSPA) will be negligible”.
This does not dispel concerns over potential for subsidence of the seafloor outside of these Protected Areas which could have impacts on the benthos plus potential consequences to shoreline profile and wave heights, which could in turn result in unintended consequences that would affect these protected sites and elsewhere.Data and understanding are limited at the present time and in order to address this, WCM will commission surveys and a numerical modelling study to more accurately predict the potential impacts, if any, of subsidence on the intertidal and marine environments, to be completed prior to commencement of works.
“Data will also be gathered regarding subtidal communities to determine the distribution, extent and likely responses of any potential sensitive receivers. In addition, a Marine Monitoring Plan will be implemented to monitor the bathymetry of the seabed and surficial sediments properties (including benthic communities) overlying the extraction zones using the data collected in 2016-17 as a baseline”.
NWIFCA would ask who the regulator for subsidence risk is and stress the need for further dialogue and engagement over this issue once predictions of potential impacts have been produced.
The NWIFCA have said that they “will respond formally to an MMO consultation”.
70 Subsidence – Investigation and reporting
WCM response
“Chapter 17 and the HRA did not come to a conclusion that this would occur. CCC have considered this 3 times and have not sought such a condition”
RFL response
It was assumed by the NWIFCA, the County Council and NGOs that the subsea impacts of this coal mine would be scrutinised by a Marine Management Organisation consultation. The onshore impacts from subsea mining induced seismicity and subsidence ( including radiological impacts and the question of who is liable should the “expected subsidence” result in resuspension of Sellafield’s wastes from the mud patch) would be one of the issues given scrutiny in a public consultation by the MMO. However, WCM have said that they “may not need” a MMO licence. What is the evidence for this statement? Has a pre- licence application been submitted behind closed doors ?
71 Subsidence – Mitigation
See above.
Refs North Western Inshore Fisheries and Conservation Authority Ref No: 4/17/9007 RE: Consultation on Further Information submitted in relation to a Mineral County Matter Application for Planning Permission accompanied by an Environmental Statement 29th January 2018 – full document attached“Offshore Subsidence – resuspension and dispersal of radioactive contaminants. The documentation has confirmed to NWIFCA that a risk of subsidence exists and therefore there remains an overwhelming concern over the potential for disturbance and resuspension of radioactive contaminants and sediments.”
The result of this would be that the seismic and subsidence issues having not been addressed by Rule 6 Parties in the Planning Inquiry will also not receive any scrutiny in a public consultation from the Marine Management Organisation. The Mineral Planning Authority of Cumbria County Council has the responsibility to manage conditions for any onshore effects and harms resulting from Woodhouse Colliery should Michael Gove approve the mine. But if their source of origin is subsea, the local planning regime outsources responsibility to the UK government’s Marine Management Organisation, from whom the developers clearly expect a rubber stamp.
If a rubber stamp is to be issued by Government (who employ the coal boss as a nuclear waste ‘disposal’ advisor at the Committee on Radioactive Waste Management https://www.gov.uk/government/people/mark-kirkbridg) it is imperative that a seismic Traffic Light System for the Woodhouse Colliery is implemented. The TLS should be at least as stringent as that for fracking.
“MORALLY INCOHERENT” In his statement to the Planning Inspector, the independent speaker and writer, formerly UK climate envoy 2006-12 John Ashton CBE included the following points. https://www.itv.com/news/border/2021-09-08/cumbria-coal-mine-inquiry-evidence-from-day-two : “it is also dysfunctional that the terrestrial and marine dimensions are being considered separately. I understand the procedural reasons. But it is the consequences of the project as a whole that will shape the lives of those in the firing line. It is both intellectually and morally incoherent, as well as administratively inefficient, to subdivide those consequences: to consider the climate implications, for example, without looking at the risks arising from the destabilization through subsidence and seismicity of Sellafield waste on the seabed above the mine.” Although the former UK Climate Envoys’ statement was widely reported the points he made on seismicity and subidence never made it into the headlines.
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.”
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.
CLICK ON THE COMMENTS ICON ABOVE TO VOTE NO..If you are on social media there is an opportunity to Vote No to the coal mine – the Whitehaven News has a poll which is so far being populated by pro-mine votes – come on lets show resistance to this diabolic plan which is far more dangerous than the sum of the climate/steel/jobs arguments being promoted.
Q. When is a Coal Mine More Dangerous than the Sum of its Parts??
A. When the Coal Mine Boss is “invaluable” to the UK Government’s Nuclear Dump Plans
This article was written in early 2017 and sent out to local and national groups and commentators with the aim of raising opposition to the coal mine – that was achieved but the many headed hydra in the room is still being studiously ignored. Our nuclear obsessed government are only too happy about that – the last thing they want is to draw attention to the insanity of mining out earthquake inducing huge voids under the Irish Sea adjacent to Sellafield. What a nightmare.
From early 2017….
Most Gaseous, Dangerous Pit in the Kingdom These are strange, confusing days. There is all round praise being heaped on the plans to reopen Whitehaven coal mine on Cumbria’s West Coast, the most gaseous, dangerous pit in the Kingdom. In 1815, Sir Humphrey Davy’s invention of the miner’s safety lamp was first tested in Whitehaven Coking Coal Mine because of its reputation for “firedamp” (methane) and fatal explosions. By 1816 the Davey lamp was in full use in collieries around Great Britain. A letter of gratitude was written by Whitehaven Miners to Sir Humphrey Davy in 1816…. many of the miners signing the letter later lost their lives in the mine. Honeycomb The West Coast of Cumbria below both ground and sea is a labyrinthine honeycomb of mines. Not only coking coal but iron ore and many other minerals. This vast honeycomb of mines stretches to Sellafield. One of the earliest records of coal mining in West Cumberland dates to 1560, the last pit, the Haig, closed in 1986. There are old mine maps but these are far, far from complete. Understandably so, given the length of time that this area has been extensively mined. Many of the miners are still there in the dangerous honeycomb. Entombed in the same collapsed and sea inundated mine pits that the West Cumbria Mining Company wants to reopen. Infamous Copeland By Election In the recent infamous Copeland by election the candidates without exception declared themselves to be “big fans” of reopening the West Cumbria Coal Mine. They did this in true Alice in Wonderland style, expressing concerns about climate change while praising the plan to reopen the coal mine. For many years UK citizens have been subjected to a constant bombardment of disingenuous propaganda: ‘nuclear power is the answer to climate change and coal is far worse than nuclear for the climate’. The purpose of this propaganda being that we should welcome nuclear with open arms, while shunning coal. George Monbiot has consistently and aggressively set the pace: “Nuclear scare stories are a gift to the truly lethal coal industry.” Monbiot’s constant mantra in the last several years is that those who oppose nuclear power are uninformed, bigoted idiots. Now it appears that the idiots in Cumbria are being groomed to welcome both coal AND nuclear. Homely Image A recent article in the Daily Mail paints a homely image of a local mining firm returning to its traditional roots in Cumbria. This image is not quite what it seems. The £14.7m private equity financing for reopening Whitehaven mine has been put up by EMR Capital who say: “We are a specialist resources private equity manager whose team has a proven track record in the three dimensions critical to achieving superior returns:
Successful resources exploration, development, operation and commercialisation
Deep linkages to Asian markets – in particular, with commodity purchasers and end users, resources companies, investors and governments
Private equity investment management”
PR Spin The PR for reopening the coal mine seems to have worked its charms on the local Allerdale and Copeland Green party for whom the coal mine gets a thumbs up as it ‘will reduce imports of the coking coal necessary to produce wind turbines.’ This argument holds no water as in order to recoup money and make a killing the coal from Whitehaven would be aggressively exported worldwide. The coal and its by-products could end up doing anything from being burnt in coal fired power stations, processed into coking coal, making the vast amounts of steel necessary for a giant geological dump for radioactive wastes. The coal from Whitehaven was first processed into coking coal for the iron industry in 1723. Coke production did not however match local demand and tonnes were brought in from Durham. The Durham coke was superior in having lower phosphorus content, a factor of importance to the local hematite iron industry. Turning the ground to a liquid mess There are other ways to achieve the high temperatures necessary for steel production but even if processing coal into coking coal was the only way, the close proximity of Sellafield and the proposed Moorside site should knock this dangerous plan on the head. Extractive activities are known to cause earthquakes. There are two contenders for the strongest earthquake in this region a 5.0 ML earthquake on 11 August 1786 had an epicentre just offshore from Whitehaven and a depth of about 16 km; a 5.1 ML earthquake on 17 March 1843 had an epicentre offshore from Barrow and a depth of about 15 km. This may not be unrelated to the escalating mining activities going on the time. The only area in the UK to have experienced a liquefaction event is the village of Rampside, near Barrow in 1865. “High intensity and liquefaction phenomena are usually associated only with relatively large magnitude earthquakes. An earthquake in 1865 in the North West of England suggests that a sufficiently shallow small event can also produce liquefaction. The effects are well documented in historical sources and include sand fountaining. Modern investigation is confined to documentary evidence owing to the tidal environment of the area where liquefaction occurred. Analysis shows that the felt area of the earthquake was probably only about 200 km2; however, heavy damage occurred in the village of Rampside and the maximum intensity is assessed at 8. Liquefaction is not uncommon at this intensity, but such a high intensity is not usually produced by such small earthquakes. The magnitude was probably in the range 2.5–3.5 ML.” pure and applied geophysics November 1998, Volume 152, Issue 4, pp 733–745 Questions West Cumbria Mining are inviting the public to ask questions so I asked the following: “How would the mine be dewatered? What is the full carbon footprint for one year of peak production. Including predicted dewatering, mining and export operations? What agreements have been made with St Bees School, Lowther Estate, regarding the mineral rights? How are the vast network of faults and dips mapped? (this would have a bearing on distance to the sea bed) What is the proximity to the proposed Moorside site and Sellafield?” The reply from Communications Manager Helen Davies was: “At this time I am busy preparing for our next major stakeholder event, which is scheduled to run on the 2nd, 3rd and 4th March. It would be much easier to discuss your questions and provide answers from our team of specialists who will be at the event, rather than attempting to answer them in writing now. The event on the 2nd March is by invitation only – please find attached an invite, we would be delighted if you could come along to meet with us. Caroline Leatherdale, our environmental specialist will be there, together with a wide range of our technical team.” Does your lump of coal feel lucky?” Marianne Birkby Radiation Free Lakeland some more info… Earthquakes http://earthwise.bgs.ac.uk/index.php/Geological_hazards,_geology_and_man,_Northern_England http://earthwise.bgs.ac.uk/index.php?title=File:P916108.jpg&filetimestamp=20160412172238& http://www.westcumbriamining.com http://www.westcumbriamining.com/local-news/west-cumbria-mining-outline-new-plans-coking-coal-mine-near-whitehaven/
Dear Tim Farron MP, URGENT – TRAFFIC LIGHT SYSTEM AS STRINGENT AS THAT FOR FRACKING NEEDED FOR FIRST DEEP COAL MINE IN 30 YEARS – JUST FIVE MILES FROM WORLD’S RISKIEST NUCLEAR WASTE SITE
At over 0.5 Fracking Operations were stopped – Not so with Cumbrian Coal Mine which would be “allowed” to induce earthquakes of 3.0 magnitude.
Thank you for sight of the reply from BEIS. Once again Anne-Marie Trevelyan MP, has refused to answer our questions. We agree that no one in their right mind – even those focussed on “Delivery” of a Geological Disposal Facility would consider putting a GDF in the vicinity of a coal mine, let alone putting heat generating nuclear waste into a coal mine.
Why then is the coal mine slap bang in the middle of the Cumbrian Irish Sea “search area” for a GDF when this subsea methane rich and faulted area is clearly “not suitable” for a GDF ? Mark Kirkbride’s coal mine plan is slap bang in the middle of this “search area.”
Once again we ask the questions:
Why is Mark Kirkbride’s coal mine included slap bang in the middle of the Irish Sea “search area” for a GDF when as the Minister has confirmed this subsea methane rich and heavily faulted area is clearly “not suitable” ?
Why has the Coal Authority not stepped in already, Blocked the Licences and prevented an expensive public inquiry for a development that local planners no longer support and is financially insecure? WCM’s latest accounts indicate financial insecurity with staff lay offs to “cut costs.” The coal mine with its high ash and high sulphur coal is no longer/never was financially viable.
Finally and perhaps most importantly but most ignored, Sellafield’s infrastructure just five miles away is at serious risk from this coal mine. On the Sellafield site, the Magnox Swarf Silo for example has unknown leaks from unknown cracks in the concrete containment which is partly beneath ground. Sellafield have last month asked for help in finding and mitigating the leak of 550 gallons per day of radioactive liquor into groundwater beneath the site from unknown cracks. Fracking was halted because of earthquakes, coal is known to induce earthquakes at a far greater magnitude than fracking. An induced tiny crack in the concrete at Sellafield is not comparable to a tiny crack anywhere else.
Yesterday on Womens’ Hour the Minister did not go so far as she has done in the reply to us in endorsing the coal mine. It is understandable, if unethical, that the Minister would defend the business interests of a key advisor to her department, BEIS. Mark Kirkbride is Chair of the Sub Group (on the Committee on Radioactive Waste Management) tasked with “Delivery” of a Geological Dispsoal and advising BEIS on how this can be achieved.
What is not understandable is that the the Minister supports the mine at the expense of public safety stating “In the highly unlikely event of the proposed mine collapsing, the assessment determined that any ensuing earth tremors would be limited to very low levels. In addition, any such tremors would not be felt on the Sellafield site, nor disrupt structures, systems, and components important to safety.” This is simply breathtaking in its nonchalance.
The limit of Peak Particle Velocity that Mark Kirkbride wants the earth movement to be set at for his mine is 6mm/sec, this is as high as the upper limit for blasting in a quarry. Even then, unlike fracking which would be halted at a much lower level the operations would continue while ‘investigations’ would take place. The vibrations of huge bolter mining and cutting machinery in multiple coal mining operations (as boasted by Mark Kirkbride) under the Irish Sea will be continuous rather than sporadic as in blasting,
At the Chaco National Heritage Park in New Mexico the limit is advised at 2mm/sec PPV for mining in order to protect the structures (https://pubs.usgs.gov/of/1985/0529/report.pdf). It is accepted that at 1.0mm/sec PPV the level would cause complaint from the public – Mark Kirkbride wants his “accepted” level to be 6mm/sec of Peak Particle Velocity. (United Utilities Guidance on human response to construction vibration page 10 of May 2014 UU Statement Cuadrilla Bowland Ltd Temporary Shale Gas Exploration PNR).
Unlike fracking , West Cumbira Mining do not propose stopping operations even if earthquakes of a far greater magnitude than 0.5 ML occur. This is outrageous given that coal mining is known to induce earthquakes of 3 ML and more.
Geologist Peter Styles in his 2018 paper said: UK Seismic Traffic Light Thresholds postulate a cessation and subsequent modification (or even halting) of fracking activities if an earthquake of magnitude 0.5 ML occurs. This size of event corresponds to a movement of only a few millimetres on a short fault segment of a larger fault. Fracking and Historic Coal Mining: Their relationship and should they coincide? by Professor Emeritus Peter Styles.
Cuadrilla’s Environment Statement Appendix L on Induced Siesmicity states. “It should be noted that the TLS (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.” Quite!
Will BEIS step up as their predeccesor DECC did and impose a seismic Traffic Light System on West Cumbria Mining? To not do so puts the whole of Europe at risk from this coal mine just five miles from Sellafield. The Lake District Boundary Fault starts at Whitehaven, to run under Sellafield and down to the Duddon Estuary. Should the Secretary of State be minded to approve this mine a Traffic Light System at least as stringent as that for fracking MUST be put in place.
Finally the Minster for BEIS states that: “The process to identify a site for a GDF is based on positive support from a willing community together with a suitable site. No sites have yet been selected”
Evidence suggests otherwise. In a document published in August by HM Treasury “Analysis of the National Infrastructure and Construction Pipeline 2021” (an advance warning of all the planned big-money spends for the UK Gov’) (LINK below) in part 7 (page 28) [a section called: Methodology Used for Regional Analysis of Investment to 2024/25] it is explained that:
“Projects in the National Infrastructure and Construction Pipeline are allocated to individual regions (as defined by the ONS), based on the location of the built asset when the asset is located within one region.”
Then at part 7.6 (also Page 28) – this is written:
“…investment in the Geological Waste Disposal Facility is allocated to the North West”
This document evidences that The Government and The Treasury have set-aside funds for a GDF in “the Northwest” for the years 2024 and 2025.
This contradicts the position that no site has yet been chosen.
It is Urgent that a Traffic Light System at least as stringent as that for fracking is put in place for this highly mechanised first deep coal mine in 30 years five miles from Sellafield
Yours sincerely Marianne Birkby on Behalf of Radiation Free Lakeland
CC Paul Haggin Cumbria County Council Planning Inspector Stephen Normington
PREVIOUS CORRESPONDENCE
16th July 2021
Dear Tim,
Thank you for sight of the reply from Anne-Marie Trevelyan MP, Minister of State for Energy, Clean Growth and Climate Change.
It was good to hear the Minister say that “I would like to reassure your constituents that Radioactive Waste Management Ltd (RWM), the developer of the GDF, has absolutely no plans to consider coal mines for the geological disposal of radioactive waste, because they are simply not suitable. ” We agree that no one in their right mind – even those focussed on “Delivery” of a Geological Disposal Facility would consider putting a GDF in the vicinity of a coal mine, let alone putting heat generating nuclear waste into a coal mine. This said we have to ask: Why is the coal mine slap bang in the middle of the Cumbria Irish Sea “search area” for a GDF when this subsea methane rich and faulted area is clearly “not suitable” for a GDF ?
CRONYISM – THE MOST BLATANT EXAMPLE EVER IN UK HISTORY?
This question of the relationship between the GDF and the Coal Mine has added piquancy given that the said Coal Mine is the business interest of Mark Kirkbride who is advising the Minister on the GDF having been appointed to a number of key positions on the Committee on Radioactive Waste Management. The Minister does not address the thorny issue of coal/nuclear/private/public cronyism in her reply to you.
To reiterate: In 2011 the same year Charles Hendry MP was prematurely congratulating Cumbria Council on their ‘steps towards geological disposal of hot nuclear wastes’, he was also cutting the ribbon on one Mark Kirkbride’s venture as CEO at Itmsoil a Sussex based International company specialising in instrumentation measuring stress in large scale construction projects. Mark Kirkbride’s Itmsoil company went into Administration in 2014 in order to give ”protection from creditors.” Charles Hendry was the predecessor of Anne-Marie Trevelyan MP, he was doing her job with the same responsibility for both the GDF and the Coal Authority.
FINANCIALLY VIABLE ?
The Minister states that the Coal Authority has to be satisfied that the coal mine must prove its financial viability before licences can be issued. We have previously made the point that the coking coal from this mine would not be the premium quality product first vaunted by WCM but would be of a high ash and high sulphur content and most likely unsaleable (as coking coal).
The latest accounts from West Cumbria Mining clearly state that the company is financially unviable. Staff have been laid off, the office in Haywards Heath has closed, the secretive financial backer is prepared to stand the cost until the end of the planning process and a third party funder says they are prepared to fund development, whatever that development is as we have not been given sight of it.
In fact No one has had sight of the latest licence applications from WCM as the Coal Authority is deferring to Mark Kirkbride’s wish not to make his development plans public. Given the relationship between WCM, CoRWM and with BEIS who have ultimate responsibility for both the Coal Authority and CoRWM this is an example of epic cronyism WCM have made much of employment of the local workforce but the Directors have a past record of using administration tactics to avoid paying creditors and then rise phoenix like into another incarnation. The amount of money spent by WCM on political lobbying (New Century Media/Tony Lodge – cosy visits by Mark Kirkbride with MP Trudy Harrison to BEIS) is in the £millions. It is clear that PR and political and financial chicanery is more important than keeping the WCM office staff on.
The paperwork has already been put into place by WCM to ensure that when it all goes pear shaped (or to plan?) WCM’s land and assets go to EMR Capital who are acting on behalf of other parties.
Further Questions include:
Why is Mark Kirkbride’s coal mine included slap bang in the middle of the Irish Sea “search area” for a GDF when as the Minister has confirmed this subsea methane rich and heavily faulted area is clearly “not suitable” ?
Why has the Coal Authority not stepped in already Blocked the Licences and prevented an expensive public inquiry for a development that local planners no longer support and is financially insecure? WCM’s latest accounts indicate financial insecurity with staff lay offs to “cut costs.” The coal mine with its high ash and high sulphur coal is no longer/never was financially viable.
Finally and perhaps most importantly but most ignored, Sellafield’s infrastructure just five miles away is at serious risk from this coal mine (notwithstanding the nonchalance of the Office for Nuclear Regulation). On the Sellafield site, the Magnox Swarf Silo for example has unknown leaks from unknown cracks in the concrete containment which is partly beneath ground. Sellafield have last month asked for help in finding and mitigating the leak of 550 gallons per day of radioactive liquor into groundwater beneath the site from unknown cracks. Fracking was halted because of earthquake risk and yet the Royal Society and the Royal Academy of Engineering have stated that coal mining induced earthquakes are of a magnitude greater than fracking : “Seismicity induced by hydraulic fracturing is likely to be of smaller magnitude than the UK’s largest natural seismic events and those induced by coal mining”. Sellafield is on the Lake District Boundary Fault and WCM plans to abstract profligate amounts of ground water from their newly voided mine via the Byerstead Fault – no one knows how these faults relate to each other. Why aren’t lessons being learnt in the Sellafield area from the fracking experience in the Blackpool area when coal mine induced seismicity is of a magnitude greater than that of fracking?
Many thanks for persisting with our questions to Ministers.
Thank you for your email dated 11 May, to the Rt Hon Kwasi Kwarteng MP, on behalf of your constituents, regarding the West Cumbria Mine. I am responding as this matter falls within my Ministerial portfolio.
There is a good deal of information about the Coal Mining licensing process, including the different types of licences and permits, available on the pages of GOV.UK. Including here: http://www.gov.uk/government/publications/surface-and-underground-coal-mining- licences/guidance-notes-for-underground-coal-mining-licences.
The Coal Authority’s duties about licensing are set out in statute – in the 1994 Coal Industry Act – and to operate a coal mine an operator needs relevant rights and permissions including planning permission, a licence from the Coal Authority and to notify the Health and Safety Executive.
In general terms planning permission covers local social, economic and environmental aspects – i.e. is this the right place for this activity? whereas, a coal mining licence considers practicalities – can the mine operate in a way that is effective and financially underpinned to ensure that any land or property impacted can be compensated and the mine eventually closed in a safe and appropriate way. The Health and Safety Executive considers whether the operations can be undertaken safely.
When assessing an application for a coal mining licence, the Coal Authority are required to consider:
Whether the applicant can finance coal mining operations and related liabilities
The nature of the land or property that may be impacted by subsidence and that damage can be properly compensated by the operator.
That the operation will be carried out by properly experienced people In the case of West Cumbria Mining, this is what the Coal Authority will be assessing in consideration of the operator’s application to extend the term of their conditional licences. A conditional licence does not allow coal mining operations to commence (the purpose of a conditional licence is explained in the link above). As you are aware, planning permission for this mine is subject to an inquiry and it would not be appropriate to comment on the outcome of that but as outlined above, the Coal Authority assesses applications to it based on the duties set out in its enabling legislation.
To disclose the financial matters and commercial activity of the mine operator would be a breach of confidence to the clauses within their licence and their commercial interests. The Coal Authority also has a duty under S59 of the Coal Industry Act 1994 to ensure that it maintains confidentiality in respect of the business affairs of any individual or a business. Whilst the Coal Authority may be asked to input on aspects such as the history of the site or the quality of the coal, its processes are distinct and separate to that of planning and therefore any planning enquiry.
Given the Coal Authority’s duties under s59 of the Coal Industry Act, the Coal Authority have advised they would not disclose details of the application without the applicant’s consent.
Your constituents are also concerned that the coal mining licence applications are in some way linked to the process to find a site for a Geological Disposal Facility (GDF).
I would like to reassure your constituents that Radioactive Waste Management Ltd (RWM), the developer of the GDF, has absolutely no plans to consider coal mines for the geological disposal of radioactive waste, because they are simply not suitable.
The process to identify a site for a GDF is based on positive support from a willing community together with a suitable site. No sites have yet been selected. Two Working Groups (the first formal step in the process) have been formed in West Cumbria – in Allerdale and in Copeland – with more expected to be announced in England later this year. It is the Working Groups which will identify the initial search areas for a location for the GDF. The site selection process will stretch over several years and the decision to go ahead at a prospective location will ultimately be subject to a test of public support. It can only proceed if the community wishes it to proceed.
Thank you once again for taking the time to write. I hope you will find this reply helpful. Yours sincerely,
THE RT HON ANNE-MARIE TREVELYAN MP
Minister of State for Energy, Clean Growth and Climate Change
The following letter has been sent to Cumbria County Council and the Planning Inquiry. Our trembling earth was the reason fracking was halted – the siesmic impacts from the Cumbrian Coal Mine are set to be far worse than that from fracking and yet there is a terrible silence – a silence that protects no-one but the coal developers and our nuclear obsessed government who want to keep Sellafield out of the behind the headlines narrative that this mine is more than the sum of its climate parts.
13th September 2020 by email
For the Attention of Paul Haggin, Manager Development Control and Sustainable Development Environment and Regulatory Servicesm, a Copy has also been sent to the Planning Inspector, Document also attached to include images.
Dear Mr Haggin,
We understand that this week the Cumbria Coal Mine Inquiry will be looking at Conditions of the 106 Agreement to be placed on Woodhouse Colliery should the Secretary of State be minded to allow the development to go ahead.
TRAFFIC LIGHT SYSTEM FOR SEISMIC IMPACTS
Radiation Free Lakeland urge the County Council to ensure that the “likely” Seismicity and “expected” Subsidence have at least the same stringent Traffic Light System TLS as was applied to the fracking industry. At present the Seismicity and Subsidence Conditions of the 106 Agreement agreed to by the Council are wholly inadequate for many reasons including:
“the first new, deep-level coal mine in the UK, for 30 years, has planning permission from Cumbria County Council – induced seismicity is likely, ” former Head of the British Geological Survey Dr Chris Browitt and Dr Alice Walker speaking at the 2019 Conference on Earthquake Risk and Engineering Towards a Resilient World.
Close Proximity to High Consequence Nuclear Hazards – Sellafield = 5 miles / Cumbrian Mud Patch (containing bulk of Sellafield’s Discharged Radioactive and Chemical Wastes = directly under / Drigg Low Level Nuclear Waste Repository = 6 miles
We agree entirely with the analysis of Cuadrilla’s Environment Statement Appendix L on Induced Siesmicity. “It should be noted that the TLS 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.”
PEAK PARTICLE VELOCITY IS SET HIGH 6mm/sec
West Cumbria Mining has in effect written its own conditions on seismicity and subsidence and we are astounded that the Peak Particle Velocity (condition 67) is set so high at 6mm/sec. To add insult to injury WCM say that “the operator shall, as soon as reasonably practicable, carry out an investigation into the reasons for that exceedance” not as in fracking that the operation is shut down immediately (at a much more stringent level). We have to ask why, when WCM are doing no blasting is the PPV set so high? Although WCM are not blasting the vibrations associated with this development will be of a more continuous nature with associated impacts.
We can only assume it is because of the enormous vibrations resulting from Tunnel boring Machines, Bolter Miners and Continous Miners. Mark Kirkbride in his statements to the Planning Inquiry has said that there will be the equivalent of multiple “mini-mines” we have to assume they will all be equipped with enormous earthshaking machinery which necessitates the PPV to be set high. To make a comparison again with fracking, this is taken from United Utilities Statement of May 2014 “Based on the assessment of induced seismicity and the predicted ground motions for a 1.5 ML event of 0.4 to 1.8mm/s, it is considered highly unlikely that the structural integrity of the gas pipelines, UU water mains, electricity cables or telecommunications cables in the vicinity of the Preston New Road site would be damaged or affected by the ground motions associated with hydraulic fracturing at the Preston New Road site.”
United Utilities Guidance on human response to construction vibration (page 10 of May 2014 UU Statement Cuadrilla Bowland Ltd Temporary Shale Gas Exploration PNR).
At exactly this time four years ago Radiation Free Lakeland raised opposition to West Cumbria Mining’s development on the grounds of Earthquakes. Subsidence and Proximity to Sellafield. Nothing has changed in those four years except that West Cumbria Mining’s ground shaking hazards so near Sellafield have been hidden in the shadow of the climate glare. We are also culpable in that respect as our legal challenge focussed on the more in vogue climate issues. In hindsight although our legal challenge went some way to delaying the mine’s scheduled 2021 opening, we should have had the courage of our convictions to entirely focus our limited resources on exposing the seismicity and proximity to Sellafield.
Cumbria County Council must not allow itself to be culpable in allowing conditions that would lead to a seismicity inducing development five miles from Sellafield. We urge the council to ensure that the issue of seismcity is addressed as stringently, as was the case with fracking at Preston New Road, in the conditions of the 106 Agreement.
A Traffic Light System that places conditions on West Cumbria Mining’s coal mine, five miles from Sellafield, that are at least as stringent as those for Fracking is vital. The high consequence impact for Cumbria and the Planet is a nuclear armageddon present and immediate should this earthquake inducing coal mine be given the go ahead by the Secretary of State.
Yours Sincerely,
Marianne Birkby
On behalf of Radiation Free Lakeland
CC. Stephen Normington, Planning Inspector, Office for Nuclear Regulation, Health and Safety Executive, Cumbrian MPs, South Lakes Action on Climate Change, Friends of the Earth, Greenpeace, Cumbria Action for Sustainability, Scientists for Global Responsibility, Nuclear Free Local Authorities, North Lakes and South Lakeland and Lancashire CND
REFERENCES:
2019 Conference on Earthquake Risk …..Abstract: Since the UK-wide seismic monitoring network was developed by BGS in the 1970s and 80s, small earthquakes in coalfields, where deep mining was taking place, were shown to be caused by the mining activity. Many of these mining induced events were felt by the Public. …10 Sept 2019
Briefing Paper sent to Cumbria County Council and the Planning Inquiry : WEST CUMBRIA MINING: WOODHOUSE COLLIERY PROPOSAL RADIOLOGICAL IMPLICATIONS of POTENTIAL SEABED SUBSIDENCE SEISMICITY & “FAULT RE-ACTIVATION” beneath The CUMBRIAN MUD PATCH: INDUCED BY “MASS REMOVAL”, RAPID EXTRACTION & VOID SPACE CREATION. by Tim Deere-Jones.
Cuadrilla Environmental Statement for Preston New Road Appendix L Induced Seismicity: 458: It should be noted that the TLS 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 observed81
September 10th 2017 “campaigners believe the proposed site is dangerously close to Sellafield. Marianne Birkby, Radiation Free Lakeland campaigner, said: “This is a small but determined rally, people have travelled from West Cumbria, Lancaster and even as away as London to stand in opposition to the coal mine. The more people know about it the more deeply angry they are at the thought of deep coal mining in such close proximity to Sellafield. We have just been speaking to a miner from Yorkshire who says the plan is absolutely the most dangerous thing he has heard of. Opponents of the mine fear that having coal drifts extend to within 8km of the Sellafield ponds, containing high level nuclear wastes, could put the public at risk. They raised concerns about the proximity of the potential mining activity to the nuclear facility.” https://www.whitehavennews.co.uk/news/17112096.campaigners-protest-over-coal-mining-plans/
Further Notes:
LIQUEFACTION – the only UK event was “The Barrow-in-Furness Earthquake of 15 February 1865: Liquefaction from a Very Small Magnitude Event” R. M. W. Musson
The susceptibility of glacigenic deposits to liquefaction under seismic loading conditions: A case study relating to nuclear site characterization in West Cumbria
“The geotechnical engineering behaviour of a sequence of glacial deposits on the Sellafield nuclear site is evaluated together with their susceptibility to potential liquefaction under certain seismic load conditions. The evaluation identified that layers of very loose to loose deposits within the ice sheet marginal landsystem are particularly susceptible to liquefaction”
MEMORANDUM TO THE PLANNING INQUIRY ON THE BYERSTEAD FAULT AND WATER ABSTRACTION
Dear Liz
Applicant’s name: West Cumbria Mining Ltd Call-in reference: APP/H0900/V/21/3271069
Please could this Memorandum be attached to our Evidence to the Public Inquiry
5/4/21 Memorandum from Radiation Free Lakeland BYERSTEAD FAULT
We would like to make it clear regarding the Byerstead Fault that County Councilors 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 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:
36. 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.
out below the level of the water table.
37. 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 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
Geotechnical experts have urged caution over claims from a campaign group that the proposed Cumbrian coal mine could cause earthquakes.
Before the start of the public inquiry into the mine – which began yesterday – campaign group Radiation Free Lakeland said that the development poses induced earthquake and subsidence risk.
The group believes that “mining induced seismicity is likely to occur” at the coal mine, and also emphasised that nuclear waste site Sellafield is 8km away.
“The majority of 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,” Radiation Free Lakeland said.
“The coal mine will induce earthquakes in the vicinity of the world’s riskiest nuclear site – that is a given – let’s hope and pray that the massive silence from NGOs over the nuclear elephant in the room does not give the government (who are employing the coal boss) wriggle room to approve the coal mine.
“We urge all those speaking against the mine at the public inquiry to give at least a mention to the fact that this coal mine would mine out voids faster than any previous coal mine in UK history and would induce earthquakes and cause subsidence in the Irish Sea and Sellafield area.”
Geotechnical specialist Clive Edmonds said that “in principle, mining can induce low magnitude, shallow depth earthquake activity”.
“Such activity has been noted in many former coal field areas where several different depth coal seams underlying each other were extracted in close proximity to fault lines,”
“Wilgeo director Phil Wilson added that “deep coal mines do cause surface tremors which could erroneously be mistaken for deep seismic events (natural earthquakes)”.
He added: “The critical issue is the magnitude of the coal mining “seismic event ” on the Richter scale, which are relatively minor in seismic terms.
“It is perhaps scaremongering to imply that these relatively minor events and surface tremors from coal mining are a hazard to nuclear facilities in Cumbria, which will have already been designed for full seismic loading on the order of 0.2g.”
“Liquefaction generally only occurs at M>5.0,” he said. “Mining induced earthquakes tend to be less than 4.0ish.”
British Geological Survey (BGS) head of seismology Dr Brian Baptie said: “Tremors in the coalfields of Britain have been reported for at least the last hundred years, and work by BGS and others led to the conclusion that these events were related to ongoing mining activity and that these were quite distinct from the natural background seismic activity of the UK.”
To accuse Radiation Free Lakeland of “scaremongering” is a nasty tactic. WCM’s advocates are misleading the public for example the ONLY liquefaction in the UK happened on the West Cumbrian coastal plain at the village of Rampside from a very low magnitude seismic event.
To suggest that Sellafield’s infrastructure is earthquake proof is also hugely misleading – for example there are cracks in the Magnox Silos that Sellafield cannot locate – radioactive liquor is leaking from these cracks at a rate of knots, millions of gallons a day – this is an already intolerable situation without the added stress to the infrastructure of induced seismicity from a highly mechanised, methane rich coal mine five miles away. “Current leak rates are circa 1.5 – 2.5 m3/d. It is desirable to reduce these as much as possible. At present, it is not possible to determine with certainty the precise location of the leak, or indeed the silo or silos (of the 6) that is leaking.” Sellafield June 2021 A tiny crack at Sellafield is not equivalent to a mining induced tiny crack in a house at Whitehaven.
Keep Cumbrian Coal in the Hole 
