Russian Government has a large slice of West Cumbria Mining New Director’s Coal Pie.
Our government are ignoring calls for diplomatic negotiations with Russia to take precedent over increasingly dangerous (and lucrative) war games while endorsing developments with ties to the Russian government. Makes no sense at all unless viewed through the business as usual at any cost lens.
Just a week after government approved the first deep coal mine in over 30 years in the UK, a new director was appointed to West Cumbria Mining.
Owen Hegarty appointed to West Cumbria Mining on 16th December 2022 is no ordinary Director. He is founder and Executive Chairman of EMR Capital, a private equity company who put up the £Millions to get West Cumbria Mining started.
In December 2020 the headline in Financial Review boldly asserted “There’s never been a better time to mine coal in Siberia” “Mining industry veteran Owen Hegarty says his Siberian coking coal venture is poised to capitalise on China’s blacklisting of Australian coal, as it embarked on an exquisitely timed $43.5 million fundraising on Wednesday. ASX-listed Tigers Realm Coal has been mining on Russia’s Pacific coast for three years”
So the new Director is an opportunist then – nothing wrong with that you might say.
However this opportunist has no qualms about accepting money from governments. In the case of Owen Hegarty’s Tigers Realm Coal, the Russian government: “The certificates of residency in the ADZ provide Tigers Realm with valuable benefits that include looser regulation, tax breaks and the ability to receive financing from Russia’s sovereign fund.” The Beringovsky Advanced Development Zone (ADZ) was created by Russian legislation to provide an attractive investment and administrative framework for investors and companies in the Russian Far East.
Without the Russian government’s largesse Owen Hegarty’s Tigers Realm Coal venture would have collapsed as according to Greenpeace’s Unearthed blog “A plan by a small Australian-listed coal company to build two massive mines in the Russian Arctic is teetering on collapse as local indigenous landowners voice their concerns, the coal price continues to crater and banks remain wary of funding the project.” The article goes on to reveal that “Before Tigers Realm Coal arrived on the scene, indigenous landowners – heavily reliant on fishing salmon – had endured a long struggle before finally winning legal title to an area of land around the Amaam lagoon, right near the site of the proposed project. The community, which actively opposed coal exploration in the region, was stunned when Tigers Realm kicked off its drilling programme in late 2010. The movement of heavy equipment over the fragile tundra impacted the protection zone of Amaam Lagoon during the crucial sockeye salmon breeding season.”
Amur Tiger (Siberian Tiger -wikipedia) food includes salmon which breed in the Amaam Lagoon.
In April 2014 Tigers Realm Coal received 36 million Australian dollars from the Russian private equity firm Baring Vostok Mining and 16 million Australian dollars from the Russian Government’s Russian Direct Investment Fund (£30M in total). According to Unearthed, Tigers Realm Coal (Tigers Realm Minerals Group TIG) have even bigger ambitions for mining in the Russian Far East.
Owen Hegarty’s appointment as Director at West Cumbria Mining hot on the heels of Government approval for the first deep coal mine in 30 years in the UK has raised not one eyebrow amongst NGOs or the press. This is despite the financial backing of WCM by Hegarty’s EMR Capital (largely from unknown sources) and the large slice of Russian ownership of Hegarty’s Tigers Realm Coal. The May 2022 AGM report for Tigers Realm Minerals Group (TIG) lists Owen Hegarty as “Independent Non-Executive Director” and “Founder of TIG”.
West Cumbria Mining have not yet found time to add Owen Hegarty to their “Meet the Team” despite the illustrious new team member receiving the Order of Australia Medal (OAM) in the June 2021 Queen’s Birthday Honours List for service to the mining and minerals sector.
It does make you wonder about the Orwellian hate directed at Russia by our government on the one hand and approving a deep coal mine near Sellafield with Russian Government backed Director Owen Hegarty on the other.
Also makes you wonder about the push for a deep nuclear dump for high level nuclear wastes, as the government advisor for the nuclear dump is CEO of WCM Mark Kirkbride. Kirkbride’s coal mine has been bankrolled by EMR Capital whose Russian government funded owner (to the tune of at least £30 Million) is now an appointed Director of West Cumbria Mining.
So much for national security – but hey we need the steel from Cumbrian coking coal to build Trident nuclear submarines to protect us all from evil Russia.
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..
Offshore area no 2 is the Licence area nearest SellafieldAs can be seen from this Coal Authority image – area number 2 has very little known coal resource (blue hatch) – nevertheless the Coal Authority has just awarded West Cumbria Mining a new licence for this area which adjoins the area under consideration for a Geological Disposal Facility. Coal boss Mark Kirkbride is an “invaluable” member of the government body (CoRWM) advising on nuclear waste. His role is largely to advise on the highly mechanised digging of holes as deep as Scafell is high. We continue to urge individuals and groups opposing the coal mine to look at the bigger picture rather than focussing narrowly on climate, jobs and coking coal. To ignore the big picture (Nuclear!!) does the planet no favours. The mine can still be stopped – we will keep you posted.
the following has been sent to press…
Over the Easter period, the Coal Authority quietly awarded the controversial Cumbrian Coal Mine new “conditional” licences. The developer West Cumbria Mining’s original conditional licences granted in 2013 were valid for 8 years. W.C.M applied for a variation to their original conditional licences in January 2021. The new applications were approved on April 13th 2022.
Nuclear safety group Radiation Free Lakeland who run the Keep Cumbrian Coal in the Hole campaign have lobbied tirelessly for details of the new licence applications to be released to public view. Despite extensive correspondence between the group and the Coal Authority including an intervention by MP Tim Farron and an internal review, all details of the licences were refused public scrutiny claiming ‘commercial sensitivity.’ Campaigners say that what can be seen is that one of the new licences awarded includes Offshore Area 2, an area of the Irish Sea Marine Conservation Zone off St Bees. The nuclear safety group say that “according to the British Geological Survey most of this area offshore of St Bees and extending towards Sellafield has no known coal reserves” They go on to say that “the awarding of coal licences to the developer ahead of the decision by the Secretary of State, Michael Gove suggests that the Inspector has recommended approval and smacks of the most blatant cronyism”.
The group point out the close relationships between the former Coal Authority Director Stephen Dingle who appointed Sir Nigel Thrift to Chair of the Committee of Radioactive Waste Management, and coal boss Mark KIrkbride, described by Sir Nigel Thrift as an “invaluable” colleague on the Committee tasked with advising government on what to do with the UK’s growing nuclear waste problem.
Marianne Birkby founder of Radiation Free Lakeland said: “there is only one thing worse than opening a new coal mine and that is opening a new coal mine near Sellafield whose boss is advising the government on the digging of big holes for heat generating nuclear wastes”
Coal Mine developers, West Cumbria Mining have asked the *Coal Authority for new licences. Do Not Rubber Stamp the Developer’s Licence to Drill.
*The Coal Authority report to the Dept of Business, Energy and Industrial Strategy. Kwasi Kwarteng MP is the Secretary of State
BLOCK WEST CUMBRIA MINING’S LICENCE TO DRILL
Leading Cumbrian Councillors had already reassessed their previous unanimous support for the first deep coal mine in decades in the UK and voted “No.” Through this No vote they have voiced their opposition alongside leading academics, scientists, politicians, the public and many organisations.
The reasons for saying No to new licences for West Cumbria Mining are not just “compelling” as Secretary of State Kwasi Kwarteng MP has stated, they are overwhelming.
There is zero need for a public inquiry at the expense of the public purse. The mine could be stopped tomorrow. All it would take is for the Coal Authority to block the developers new applications for a Licence to Drill. It is shocking that details of the new licence applications are being kept secret and from public scrutiny despite Freedom of Information requests from nuclear safety group Radiation Free Lakeland.
CLIMATE AND NUCLEAR SAFETY …OR RECKLESSNESS?
A block on the developer’s new applications for a Licence to Drill would not only save the public purse the huge expense of a public inquiry it would also send a strong message to the UK and our international neighbours that the Department of Business, Energy and Industrial Strategy, who are responsible for the Coal Authority, are committed to both climate and nuclear safety.
While the significant climate impacts of this coal mine would be EXACTLY the same if this development had been proposed anywhere else in the UK, this coal mine is NOT JUST ANYWHERE in the UK. The mine would be largely subsea off the West Coast of Cumbria, would extend to within five miles of the WORLD”S RISKIEST NUCLEAR WASTE SITE and be directly under a massive nuclear waste dump known as the Sellafield Mud Patch.
COAL MINE UNDER AN EXISTING NUCLEAR WASTE DUMP?
Sellafield has been pumping eight million litres of “low level” radioactive discharges into the Irish Sea every day. It been doing that for decades and nuclear wastes (military and ‘civil’) still continue to arrive in West Cumbria. The nuclear waste discharge pipeline out to the Irish Sea is in constant use. The coal mine developers say there would be “EXPECTED SUBSIDENCE” of the Irish Sea bed. Recent reports have indicated this would most likely result in the resuspension of decades worth of Sellafield’s radioactive wastes now largely (but not completely) immobilised in the Irish Sea bed. Radioactive wastes including plutonium would be resuspended back into the water column, to ours and to neighbouring shores. The one thing not to do with a radioactive waste dump is disturb it.
COAL MINE ADJACENT TO A NEW HIGH LEVEL NUCLEAR WASTE DUMP?
The mine itself would be adjacent to the area being promoted as a “possible” Geological Disposal Facility for heat generating nuclear wastes under the Irish Sea. The CEO of the coal mine Mark Kirkbride has been appointed to the Committee on Radioactive Waste Management to advise government on “Delivery” of a Geological Disposal Facility (GDF). The proposed coal mine would make a void of 136 million square metres. Would this handy hole be used to dump mountains of rock spoil excavated for a GDF from neighboring rocks? What destabilising impact would this have on the neighbouring rocks? Is there a massive unresolvable conflict of interest at the heart of the forthcoming coal mine public inquiry? The final decision about the climate and nuclear dump-wrecking mine will rest with the government – the same government who have appointed the coal mine boss to position of top government nuclear dump advisor (for highly active wastes).
FARCICAL PUBLIC INQUIRY?
These questions (and more) should, but are not likely to be within the remit of a forthcoming public inquiry focussing on planning rather than key issues of governance and nuclear safety.
PUBLIC MONEY
The public have already paid out £millions for this coal mine, to be precise, £2.5 Million in Heritage Lottery Funds for the Haig Colliery Museum which was then handed over to the developers for £1.
This is a coal mine that the public would keep paying for in more than money and climate impacts – the many headed hydra of both a slow burn and immediate nuclear catastrophe are overwhelming.
There is no credible case for this mine either on the basis of finance (no market), climate (flies in face of COP26) or arguably the most serious concern, nuclear safety (under decades of nuclear waste, undermining the geology near the world’s riskiest nuclear waste site Sellafield).
BLOCK WEST CUMBRIA MINING’S LICENCE TO DRILL!
DO IT NOW
References
BEIS Ministerial Responsibility for the Coal Authority, BEIS also responsible for the Committee on Radioactive Waste Management where coal boss Mark Kirkbride is a key member.
“Ministerial responsibility 11. The Secretary of State for Business, Energy and Industrial Strategy is accountable to Parliament for the activities and performance of the Authority and it is proposed that any new Minister with responsibility for the Authority will carry out a visit to the Authority within six months of taking up appointment to learn about the role of the Authority and its functions. Typically, we would expect the chair and chief executive to meet with the minister at least annually. 12. Specific responsibilities include: approving the Authority’s overall strategic objectives and the policy and performance frameworkwithin which the Authority operates (as set out in this framework document and associated documents keeping Parliament informed about the Authority’s performance approving the amount of grant-in-aid/grant/other funds to be paid to the Authority, and securing Parliamentary approval carrying out responsibilities specified in the Act including appointments to the board, determining the terms and conditions of board members, consenting to the appointment of the, approval of terms and conditions of staff (Including pay) in accordance with the latest pay guidance laying of the annual report and accounts before Parliament”
Sellafield Radioactive Discharge on the Irish Sea Bed directly beneath the coal mine plan and question of ‘Who is Responsible for Safety of the Discharged Nuclear Wastes?’ is subject to complaint being dealt with by the Information Commissioner
Who is Responsible for Radioactive Waste on the Irish Sea Bed – Call from Nuclear Free Local Authorities NFLA troubled by the UK Communities Minister not ‘calling in’ the decision over a deep underground coal mine in West Cumbria
Thanks to Whitehaven News and local press for exposing the fact that rock characterisation boreholes have already been drilled at the ‘Low Level Waste Repository’ to prepare the way for Near Surface Disposal of Intermediate Level Wastes. We note the industry response: ” this study is separate from ongoing activities to find a suitable site for a Geological Disposal Facility”
This quite frankly is a big fat lie. The coal boss Mark Kirkbride, with his hat on as key member of the Committee on Radioactive Waste Management, has provided costings to Government on “co-location” of Near Surface and Geological Disposal. In other words the Near Surface Disposal (NSD) facility for Intermediate Level Wastes would be up to 120 metres underground in silos. The infrastructure of the NSD above ground facilities, including security, access and the like would be shared with a Geological Disposal dump to “cut costs.”
Here below is the Press Release we sent out to all national and local press as you can see the “co-location” issue is highlighted as is coal boss, Mark Kirkbride’s role as key advisor. The media, with the exception of the Isle of Man have shown remarkable solidarity in omitting any reference to the conflict of interest and cronyism regarding coal boss, Mark Kirkbride’s 2019 Government appointed role in the push for nuclear waste dumping.
PRESS RELEASE
CUMBRIA COAL BOSS’ COSTINGS ON DEEP AND NOT SO DEEP BURIAL OF NUCLEAR WASTE DUE ANY DAY – “CONFLICT OF INTEREST” WITH MINING BUSINESS INTERESTS
Costs for the underground burial of nuclear wastes are due to be published shortly by the Committee on Radioactive Waste Management (CoRWM), campaigners have learnt. The Department of Business, Energy and Industrial Strategy (BEIS) have tasked the CEO of West Cumbria Mining and CoRWM member, Mark Kirkbride with providing costings for geological and near surface disposal of high and intermediate level nuclear wastes.
Ever since the appointment of Mark Kirkbride to CoRWM in 2019, nuclear safety group Radiation Free Lakeland have argued that there is a deep conflict of interest at the heart of government on this issue. Government on the one hand will have the final say on Mark Kirkbride’s coal mine business interests and on the other hand are employing Mr Kirkbride to provide costings and “invaluable” advice on the burial of nuclear wastes. The Geological Disposal Facility is a major infrastructure project and is described by BEIS as “one of the most significant long-term environmental protection projects ever undertaken in the UK.”
Peaceful Demo at Drigg – on the Edge of the Lake District
Supporters of Radiation Free Lakeland’s new campaign Lakes Against Nuclear Dump (L.A.N.D) held a peaceful demonstration outside the Mid-Copeland Community Partnership “drop-in” at Drigg on Friday 11th March. L.A.N.D said “Drigg residents have been surprised to learn that 16 research boreholes 120 metres deep have already been drilled without any democratic oversight at the Low Level Waste Repository. The boreholes are part of a “feasibility study” for possible Near Surface Disposal of Intermediate Level Nuclear Wastes. Government policy would have to be amended for Near Surface Disposal to take place. L.A.N.D say “Locals at Drigg have every right to be angry about this. A map released under Freedom of Information as well as showing recently acquired long lease of the Drigg dunes shows the mining/mineral rights owned by the NDA and clearly shows a linked route from the Low Level Waste Repository area to the Inshore area of the Irish Sea. The mining and mineral rights mean that the NDA are able to extract rock without reference to anyone else.”
Freedom of Information answers have revealed that: “The Nuclear Decommissioning Authority (NDA) has asked LLWR to conduct a feasibility study to assess the capacity of the LLWR site as part of their wider studies on near-surface disposal.
.. It includes the drilling of new characterisation
and monitoring boreholes that reach a maximum depth of 120 metres. All of
which are within the LLWR site boundary.”
“Co-Locate” to “cut costs”
The Nuclear Decommissioning Authority have stated in their 2020 position paper on Near Surface Disposal that “The assessment of disposal costs has been made on the assumption that a nearer- surface disposal facility ..would be co-located with a GDF.” This is say L.A.N.D a breach of trust regarding the nuclear waste plans and they have
sent a 30 page report “Nuclear Waste’s Shifting Sands On the Lakeland Fringe” to Allerdale and Copeland Community Partnership members with a letter urging them to withdraw from the “Community Partnership” which they have branded “fraudulent”.
“Protected” ?
The Mid-Copeland Community Partnership “Drop-In” at Drigg on Friday told Drigg locals that the 16 research boreholes drilled without any democratic scrutiny “are nothing to do with us.” Meanwhile, coal boss, Mark Kirkbride’s costings for the Near Surface and Geological Disposal of Intermediate and High Level Nuclear Wastes are due to be published any day now on the Committee on Radioactive Waste Management’s website. A decision on Mark Kirkbride’s coal mine is also due to be made by Secretary of State Michael Gove. In another twist of logic both the subsea coal mine and the subsea GDF would be within the West of Copeland area of the Irish Sea designated as a Marine Conservation Zone by Michael Gove in 2019.
A great article by Paul Brown below – there is however a big elephant in the room regarding this story. The elephant in the room is the Cumbrian Mud Patch – the radioactive silts on the Irish Sea bed resulting from decades of reprocessing. The coal mine due to be decided upon soon by Government (after Planning Inspector Stephen Normington makes his recommendation) would churn up this nuclear crapola on the seabed. A tsunami of radioactive wastes now largely inert (apart from tidal processes) would be resuspended in the water column – returning to the shores and to the rest of the world. It takes only 4 years for Sellafield’s seaborne waste to reach the Arctic. The coal mine would cause subsidence and resulting resuspension of nuclear wastes. The coal mine would cause earthquakes. Both these outcomes are not “likely” they are certain. The coal mine CEO is also employed by government as advisor on the plans for a deep (and not so deep) nuclear dump for heat generating nuclear wastes – you couldn’t make it up.
Sellafield nuclear plant. Photo by Dafydd Waters/Creative Commons.
Seventy years after the United Kingdom first began extracting plutonium from spent uranium fuel to make nuclear weapons, the industry is finally calling a halt to reprocessing, leaving the country with 120 tons of the metal, the biggest stockpile in the world. However, the government has no idea what to do with it.
Having spent hundreds of billions of pounds producing plutonium in a series of plants at Sellafield in the Lake District, the UK policy is to store it indefinitely—or until it can come up with a better idea. There is also 90,000 tons of less dangerous depleted uranium in warehouses in the UK, also without an end use.
Plans to use plutonium in fast breeder reactors and then mixed with uranium as a fuel for existing fission reactors have long ago been abandoned as too expensive, unworkable, or sometimes both. Even burning plutonium as a fuel, while technically possible, is very costly.
The closing of the last reprocessing plant, as with all nuclear endeavours, does not mean the end of the industry, in fact it will take at least another century to dismantle the many buildings and clean up the waste. In the meantime, it is costing £3 billion a year to keep the site safe.
Perhaps one of the strangest aspects of this story to outside observers is that, apart from a minority of anti-nuclear campaigners, this plutonium factory in one of prettiest parts of England hardly ever gets discussed or mentioned by the UK’s two main political parties. Neither has ever objected to what seems on paper to be a colossal waste of money.
The secret of this silence is that the parliamentary seats in the Lake District are all politically on a knife-edge. No candidate for either Conservative or Labour can afford to be anti-nuclear, otherwise the seat would certainly go to the opposition party.
The story of Sellafield matters, however, particularly to countries like Japan, which is poised to open its own reprocessing works at Rokkasho, Aomori in September. Strangely, too, this is one of Japan’s most scenic areas.
This plan is particularly controversial in a country that is the only one so far to have had nuclear bombs used against it. Like Britain, Japan has no obvious outlet for the plutonium it will produce, except nuclear weapons and fast breeder reactors, this last a technology Japan has already tried and has ended in failure. It also seems unnecessary because Japan already owns a plutonium stockpile of several tonnes from sending spent fuel to the UK to be reprocessed.
While there is much more opposition in Japan, including from the influential New Diplomacy Initiative, there is local support for the works because politicians see employment opportunities. But there is also international concern about the potential spread of nuclear weapon capability to Japan and beyond.
In Britain, reprocessing began in 1952 entirely as a military endeavour. The idea was to make hydrogen bombs so Britain could keep up with the United States and Russia in the nuclear arms race.
A much larger plant opened in 1964, and it is this one that is finally due to close this year. It had a nominal capacity to reprocess 1,500 tonnes of spent fuel a year for both military and civilian purposes. It reprocessed fuel from the UK’s 26 Magnox, Italy’s Latina, and Japan’s Tokai Magnox nuclear reactors. It has reprocessed 45,000 tonnes so far and has 318 more to go.
From its inception, the reprocessing works was a highly polluting plant, discharging contaminated water into the Irish Sea. Plutonium, cesium, and other radionuclides were sent out to sea in a mile-long pipeline. Radioactivity was picked up in shellfish in Ireland, Norway, and Denmark, and in local seafood that had to be tested regularly to see if the radioactive load they carried made them too dangerous to eat. Local people were advised to keep their consumption of shellfish low. These discharges have now been considerably cleaned up.
A third “recycling” project, the Thermal Oxide Reprocessing Plant (THORP), was planned in 1977, expected to capitalize on the then projected expansion of nuclear power and to provide plutonium and uranium for newer reactors, and for the still-hoped-for fast breeder reactor programme. Government approval was given nine years later, by which time contracts for reprocessing had been made with a number of foreign companies. The new plant’s biggest customer was Japan.
So in the end, reprocessing became a commercial venture rather than producing anything useful. Nine countries sent spent fuel to Sellafield to have plutonium and uranium extracted for reuse and paid a great deal of money to do so. In reality, very little of either metal has ever been used because mixed oxide fuels were too expensive, and fast breeder reactors could never be scaled up sufficiently to be economic.
The Nuclear Decommissioning Authority (NDA), the UK government body now charged with keeping Sellafield safe and ultimately dismantling it, still makes £820 million (US$1.16 billion) a year storing spent fuel, plutonium, uranium, and nuclear waste for foreign governments and the UK’s Ministry of Defence. This latter waste includes the radioactive material from powering nuclear submarines and manufacturing bombs and warheads. The rest of the £3.345 billion (US$4.570) budget comes from the UK taxpayer.
In its current plan, the NDA hopes to have disposed of all spent fuel by 2125—103 years hence. All buildings will be demolished or reused by 2133.
Although these targets seem a long way off, some of the interim ones are already unlikely. The documents say the NDA hopes to establish a deep depository for high-level waste by 2040—but the UK government has been looking for a site since 1980, and every one “found” has so far been rejected. It has just started the search all over again, offering lots of financial incentives to local communities to consider the idea.
Whatever happens, one thing is certain—most of the 11,000 people currently employed at Sellafield will still have jobs for decades to come.
This article first appeared on The Energy Mix and is available for republication through the commons.
“Flying Underwater – Black Guillemots at St Bees”. The last nesting place of Black Guillemots in England is St Bees where the first deep coal mine in 30 years will soon be decided upon.
The Coal Mine planning inspector Stephen Normington will, any day now, be making his recommendation to government (the same government who have appointed the coal boss as nuclear dump advisor).
Then the final decision will be with Secretary of State Michael Gove on whether or not to open a new coal mine under the Marine Conservation Zone off St Bees and just five miles from Sellafield.
Concerns, aside from climate, raised by Keep Cumbrian Coal in the Hole since 2017, regarding seismic, nuclear and marine impacts have been well and truly ‘talked over’ despite our vehement campaigning.
The narrowed narrative allowed in the media (with rare exceptions) and siezed upon by NGOs (with rare exceptions) has been to focus myopically on climate ignoring all other arguably more important impacts such as seismicity, Sellafield, and putting the infrastructure in place for a deep nuclear dump.
The climate impacts of this coal mine would be the same anywhere – but this is not anywhere and the CEO of the coal mine, Mark Kirkbride, key advisor to government on nuclear dump plans, is not your ordinary everyday coal boss.
The following letter has just been sent to the Coal Mine Planning Inspector Mr Stephen Normington following a letter from the Rt Hon Greg Hands, Minister of State for Energy, Clean Growth and Climate Change (this Govnt department appointed the coal mine boss as “invaluable” nuclear dump advisor).
Dear Planning Inquiry Inspector Mr Stephen Normington,
Happy New Year to you and yours.
We, Radiation Free Lakeland (who run the Keep Cumbrian Coal in the Hole campaign) are aware that you will shortly be making a recommendation to the Secretary of State on West Cumbria Mining’s coal mine plan.
We would like to draw your attention to a letter (attached) we have received from the Rt Hon Greg Hands, Minister of State for Energy, Clean Growth and Climate Change. The reply is to our letter requesting that, should the coal mine be approved by government, then a seismic Traffic Light System at least as stringent as that for the oil and gas industry should be part of the conditions imposed. The empirical evidence (presented by Radiation Free Lakeland at the Planning Inquiry) is unequivocal in its findings that coal mining produces earthquakes of far greater magnitude and frequency than that of fracking. Despite this Greg Hands MP states that there will be no Traffic Light System for the coal mine.
In tandem with the absence of a seismic Traffic Light System is the outrageous allowance of 6mm/s Peak Particle Velocity as agreed by the Inquiry’s Rule 6 Parties and Developer for ground movements as a result of the deep mining proposed. As you will be aware the PPV at which “receptors” will make complaints is 1mm/s.
An observer of the bulk of the Planning Inquiry would have had no idea of the uniquely dangerous sense of place regarding the planned coal mine. If this same coal mine was anywhere in the world the climate impacts would be the same. But this coal mine is not anywhere in the world. It is five miles from Sellafield, the worlds riskiest nuclear waste site, under the arguably most radioactively contaminated sea in the world and directly beneath the radioactively contaminated Cumbrian Mud Patch.
You will see In his reply to us the Minister answers a question we did not ask – namely the use of the coal mine as a nuclear dump – no one in their right mind would think of using a coal mine as a nuclear dump, our concerns lay with the undeniable connections/cronyism between the coal mine and the proposed Geological Disposal Facility.
The Government’s refusal to consider a seismic Traffic Light System for the earthquake inducing coal mine is a case in point.
Mark Kirkbride the CEO of West Cumbria Mining was appointed in 2019 as an “invaluable” adviser to the Government (Committee on Radioactive Waste Management) on the digging of big holes for a Geological Disposal Facility for Heat Generating Nuclear Wastes and for shallower Near Surface Disposal of Low and Intermediate Level Nuclear Wastes.
We are painfully aware, as no doubt is government nuclear dump advisor Mark Kirkbride, that a seismic Traffic Light System for an earthquake inducing deep undersea coal mine would also impact negatively on the facilitation of an even deeper hole for a GDF. The Irish Sea area adjacent to the coal mine is in the frame for a GDF.
We urge you to take all these related issues into consideration and emphatically advise refusal for the deep coal mine which is far more than the sum of its (more widely reported) climate/jobs parts. Should this coal mine go ahead the people and environment of Cumbria and the planet WILL be exposed to deep radiological, immediate and irreversible impacts that will make the more widely reported and not to be sneezed at climate impacts pale into insignificance.
The whole thing feels like a massive stitch up in which the climate issues have been used as a smoke screen to hide the nuclear impacts of this coal mine. If Leonardo DiCaprio (of “Don’t Look Up” fame) thinks climate campaigners have it bad he should walk a mile in the shoes of nuclear safety campaigners!
Please ensure the safety of Cumbria and the planet by emphatically advising refusal for this out of control deep coal mine five miles from Sellafield.
Thank You.
Yours sincerely,
Marianne Birkby Radiation Free Lakeland who run the Keep Cumbrian Coal in the Hole campaign
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.
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.
Keep Cumbrian Coal in the Hole 