There are many reasons to object to the plan for the first deep coal mine in the UK for 30 years. The North Western Inshore Fisheries and Conservation Authority has voiced concerns. They highlight the following concern which is uniquely perilous to this area of the Irish Sea:
“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.”
Keep Cumbrian Coal in the Hole along with others have also highlighted this specific concern and would draw the Development Control and Regulation Committee’s attention to this photograph supplied to us by the Low Level Radiation Campaign
This is what radiation does to plastic
The centre of this image shows radiation tracks from a particle found near Sellafield. This is what radiation does to plastic. The Low Level Radiation Campaign tell us “it’s probably Plutonium, and about 1 micron diameter. Official reports since 1989 state that the Bristol Channel contains radioactivity from Sellafield. Since 1965 Hinkley Point also has discharged particles. Evidence that particles like this are present in the sediment has been covered up. When inhaled they are likely to be scavenged to lymph nodes. They deliver high doses of radiation to whatever body tissue they lodge in.” Plutonium is found being washed up on West Cumbrian beaches from radioactive wastes discharged to the Irish Sea from Sellafield reprocessing. Seabed subsidence would dramatically increase the “natural” resuspension of Sellafield wastes from the seabed.
More from the North Western Inshore Fisheries and Conservation Authority below.
“The North Western Inshore Fisheries and Conservation Authority is the relevant body for the regulation of inshore sea fisheries within its District. It has a range of duties including sustainably managing the exploitation of sea fisheries resources and balancing the social and economic benefits of exploiting resources with the need to protect the marine environment.
Issues of concern to the NWIFCA regarding potential impacts on the coastal and marine environment relate to all marine and coastal areas located near to the project that could be impacted, not just Marine Protected Areas (MPAs) – Natura 2000 sites, SSSI and Marine Conservation Zones in this case. There are legal procedures for assessing risk and impacts on protected sites and obligations for minimising / mitigating against these risks. However NWIFCA would ask that assessments take a broader approach and consider any risk posed to all of the coastal / marine environment within the zone of effect.
Details of many of the aspects of the development are naturally currently relatively sketchy and it is therefore not possible to provide in-depth response. However at this stage there are areas of concern highlighted below.
Issues of particular concern are outlined as follows:
- Dewatering of mine and discharge – will require an environmental permit to discharge from the Environment Agency. The level of pre-discharge treatment that the water will require and the discharge limits are yet to be set, and require more detailed assessment of the chemistry of the water within the anhydrite mine. It is noted that West Cumbria Mining is also to carry out a series of modelling and assessments of impact of the water on the marine environment.The documentation states that “At this stage it is not possible to model how the discharged water will disperse, and therefore it is not possible to accurately predict what effect there might be on the local” … fish and invertebrate life.
Until this data is obtained, firmer proposals are put forward and dispersal modelling has been completed the NWIFCA will continue to have serious concerns about the risk posed by contaminated water affecting coastal and marine environments and would request full continuing consultation and engagement with EA permitting over this aspect of the mine development.
It is noted that WCM will conduct a wide-ranging marine environmental baseline monitoring study in support of the application to be made to the Environment Agency for a Permit to Discharge the mine water to sea. NWIFCA would request early sight of the study’s results to assist in our future responses.
It is understood that the water taken from the anhydrite mine will be subject to continuous monitoring, to ensure that it continues to meet the water quality standard set by the Environment Agency. NWIFCA would request it is fully engaged in discussion over the nature of the monitoring subject to results of the water chemistry and assessed level of risk.
- Position of the discharge pipeline and diffuser – will be subject to an MMO Marine Licence application at which point NWIFCA will respond formally to an MMO consultation. Until more detailed particulars are decided for pipeline specification and position NWIFCA reserves concerns over impacts on coastal and intertidal habitats and species.At this stage NWIFCA would ask that the design ensures that all outfall pipeline discharge is below the lowest astronomical tide to prevent risk of impact on intertidal areas.
- Further potential impacts on coastal and marine systems could be impacted by the following during construction of the mine and its associated infrastructure:
- Physical mobilisation (such as soil erosion, run-off and sediment deposition);
- Disturbance of existing contaminated soils during earthworks or increased infiltration;
- Leaching once the soil is removed and areas of open excavations are exposed.
The NWIFCA notes that construction works will be managed under a Construction Environment Management Plan (CEMP) that will be developed post-planning determination, and would request early sight of the plan once drafted. As above NWIFCA reserves concerns over the risk of contaminated water reaching the coastal and marine waters until further detail has been put forward.
- Storm water discharge – NWIFCA has learned from the documentation that during the operational phase, the anticipated discharge of excess storm water flows from the site into the sea via the existing outfall has the potential to provide a pathway for contaminants into the marine environment. These flows will be sporadic and unpredictable in nature. WCM state that drainage and water treatment infrastructure on-site will be designed to ensure that storm flows are passed through silt traps and oil interceptors and to enable flows to be discharged at a controlled rate to ensure that any significant influx of storm water into the marine environment does not occur.As a result WCM consider that the risk of the storm water discharge leading to adverse operational phase effects are considered be negligible. An Environmental Permit for this discharge will be required and NWIFCA deigns to Environment Agency advice on this point.
- Offshore Subsidence – 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.
- 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.