Plutonium, Public Money and a Perilous Nuclear Dump on the Lake District Coast, a Letter to Cumberland Council’s “Nuclear Issues Board"

Sent by Email 19th September 2025

For consideration by the Nuclear Issues Board

of Cumberland Council on Monday 22nd Sept 2025

Dear Nuclear Issues Board of Cumberland Council

On 14 October 2021, Copeland Borough Council’s Executive of just four councillors took the decision to establish two Geological Disposal Facility (GDF) Community Partnerships in accordance with the UK Government’s “GDF siting process”

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West Cumbria is predictably the only consideration by NWS as a potential site for a GDF (also known as a nuclear waste dump for the abandonment of high level wastes).

A lot has changed since those four Copeland councillors put forward the Lake District coast as a sacrifice zone for the UK’s nuclear waste geological disposal plan.

We urge the Nuclear Issues Board to exercise their democratic duty and call for a debate by the Full Cumberland Council and a Full vote before going any further in the partnership with Nuclear Waste

Services for delivery of a very deep, very hot and very experimental nuclear waste dump for high level wastes.

There is no democratic mandate to continue in partnership with Nuclear Waste Services in delivery of a GDF for the following reasons:

Community Unwillingness.

Despite the ongoing Community Partnership funding, Millom Town Council and Whicham Parish Council have both withdrawn from the South Copeland Community Partnership. Whicham PC also held a parish poll that clearly indicated a 77% majority against the GDF . Millom Without Parish Council will be consulting its parishioners on withdrawal. An external review of the SCCP also found the Partnership to be totally dysfunctional with infighting between community representatives and NWS staff.

The Community of Seascale within the Mid-Copeland Community Partnership have also voiced opposition. Seascale Parish Council talked about GDF's potential area of focus for Headworks and were shown a map of a potential area for Seascale: “as a Parish Council we rejected the proposal as it was not suitable for Seascale at all, but there needs to be more that just our voice, attached is a map of the proposed Headworks location for Seascale.. We encourage residents to attend these events with GDF and voice their concerns too.”

It is ironic, given the above, that one of the Copeland (now Cumberland) councillors who took the delegated decision to 'volunteer' the West Cumbrian coastline once again into the nuclear dump plan is Vice chair of Seascale Parish Council.It is clear that previous geological work, public inquiries and Cumbria County Council resolutions on this subject are being ignored in order to proceed with a clearly unwanted, expensive, ultimately public money and time wasting project once more, casting known and unknown blight on communities for decades to come. As Martin Lowe of Close Capenhurst has observed “Cumberland Council have a duty of care to the public which this development flies in the face of.”

Increase of the mine footprint from 25km2 to 36km2 since Copeland Executive volunteered the Lake District coast.

Initially NWS literature stated that the mine footprint would be 25km2. A letter to Lakes Against Nuclear Dump from Nuclear Waste Services states that the footprint would now be 36km2 (or larger).

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Increase in heat of the “thermal footprint” of the GDF from 100 degrees c to 200 degrees c.

100 degrees c is the maximum heat “allowed” to try to ensure integrity of the bentonite buffer (clay slurry to be pumped into the mine as backfill and to delay leakage), however the thermal footprint has been increased to 200 degrees c as confirmed in a letter to Lakes Against Nuclear Dump from Nuclear Waste Services.

Inclusion of Plutonium along with High Level Wastes.

The inclusion of plutonium for burial in a GDF is a new, experimental and dangerous concept. There are unresolved (and likely unresolvable) difficulties of containing the radiotoxic nature and criticality of plutonium in a geological disposal facility.

“The problems of criticality and toxicity to the biosphere essentially come down to water—it creates the conditions for potential criticality and provides the transport mechanism for plutonium’s toxicity.” (Plutonium—the complex and ‘forever’ radiotoxic element of nuclear waste. How exactly should we manage its containment? Nick Scarr 22/08/25).

Top geologists call the plan “dangerous”

- this is why…

Professor Stuart Haszeldine, Professor of Carbon Capture and Storage, School of Geosciences Edinburgh Climate Change Institute said: “Making waste into specialised solid compounds can help to become more resistant to dissolution in groundwater. But the heat generated from the radioactive decay of isotopes is not affected by that re-engineering. Adding material which may heat to 100-200C is a huge disruption and will undoubtedly change the pathways of groundwater flow. This is like having an electric kettle containing stable stationary water and then turning on the electricity to add heat – the water soon circulates and if heating continues, the water boils.”

Professor Haszeldine added: “Have the developers actually made computer predictions of these effects in this GDF? Because plutonium has isotopes which can last for thousands of years, it may be sensible to spread that through the GDF to minimise heating – but that will make predictions of containment in circulating hot water much more difficult. It’s perfectly reasonable to think of a 150C-200C heat source at 0.5km, producing a geyser of boiling water intermittently erupting at surface temperatures above boiling.”

The spread of this increased temperature, known as a thermal pulse, would be conducted through the rock over several thousand years. With the additional pressure of water column above the GDF (a hypothetical 500m below the surface), water would boil at the higher temperature of 250C, in which case superheated steam may also occur. There is currently no guarantee that the maximum heat of the GDF will remain at 200C.

Even a 1.0C increase in ocean water [ii]can cause ‘massive impacts’ on the health of sea life and contribute to marine desertification, including loss of biodiversity, collapse of fisheries, and accelerated climate change. The proposed GDF is planned to be at least 37 km3, a substantial section of seabed under the Irish Sea, in a Marine Protected Area. Similar to nature reserves or SSSIs, Marine Protected Areas are parts of the ocean established to protect habitats, species and healthy, functioning marine ecosystems. Professor Haszeldine pointed out that seeps of warm or hot waterfrom a GDF onto the seabed are unlikely to stabilise, repair, and rewild the natural seabed ecosystems.

Professor David K. Smythe, Emeritus Professor of Geophysics, University of Glasgow, said he agreed with Professor Haszeldine about the danger of trying to bury High Level Waste, whether it was conditioned or not. “The waste should be kept on the surface of the earth, and immobilised beyond any possibility of re-use, until a proper long-term solution is found.”

For all these reasons and many more, thousands of people including hundreds of Cumbrians have signed a petition urging a debate and vote by the FULL CUMBERLAND COUNCIL before going any further in the partnership with Nuclear Waste Services for delivery of an experimental and uniquely dangerous plan to abandon nuclear wastes.

We urge the Nuclear Issues Board to exercise their democratic duty and call for a full debate and vote by Cumberland Council. Currently there is no democratic mandate to continue with the GDF “process” without at least carrying out a full debate and full vote by all Cumberland Councillors.

Yours sincerely,

Marianne Birkby, Lakes Against Nuclear Dump, a Radiation Free Lakeland campaign

https://www.lakesagainstnucleardump.com/

Richard Outram, Secretary of the UK/Ireland Nuclear Free Local Authorities (NFLAs)

https://www.nuclearpolicy.info/

Martyn Lowe, Close Capenhurst Campaign

http://close-capenhurst.org.uk/

Heat

The industry previously indicated that the maximum heat would be limited to 100C (to try to protect integrity of containment) , but Nuclear Waste Services has since revised it to 200C. The world’s first GDF, Onkalo in Finland, stipulates no more than 100C.

Unwilling Communities along the Lake District’s West Coast

Whicham Parish Poll. https://www.bbc.co.uk/news/articles/c0jvjx8kn5xo

Millom Town Council joins Whicham in opposition to GDF

https://www.nuclearpolicy.info/news/two-down-whicham-joins-millom-in-withdrawing-from-undemocratic-and-discredited-community-partnership/

Seascale Parish Council does not want GDF “near village”

https://www.nuclearpolicy.info/news/trouble-at-tmill-local-councils-rebel-over-nuke-dump-plan/

Thermal Footprint correspondence with Nuclear Waste Services

Dear Marianne

Thank you for contacting us on 3 May 2025 regarding your further questions.

We refer to the statement previously made: Design of the GDF will take account of the thermal output of heat generating waste such that it does not adversely impact the engineered barriers (backfill, plugs, seals) and containment function of the host geology (it’s ability to limit the migration ofradioactivity). This is achieved by passive means, for example, by appropriate design of the container, disposal tunnels or vaults, and spacing of containers. NWS will set a limit on the peak temperature of the GDF system and waste packages to assure the integrity of the waste, waste container, engineered barriers and host rock. The limits adopted by international programmes are typically in the range of 100oC – 200oC.

Therefore:

1. What would happen if the heat did not dissipate as intended and reached over 200 degrees c?

This cannot occur because the temperature limit applied to acceptance of the waste package, coupled with the design, means that the temperature will be controlled within the acceptable range.

2. What is meant by “no significant temperature rise on the sea-bed? What would the temperature rise be?

The temperature rise on the sea bed would not be measurably different with / without the waste emplaced.

3. Has any specific research been done to validate “no significant temperature rise on the

sea-bed”

The generic Disposal System Safety Case sets out the requirements for managing the heat output of waste, leading to the temperature limit applied to waste acceptance of waste, based on research, such that the temperature will be controlled within the acceptable range. This will be addressed in a site-specific context as site characterisation progresses and the uncertainty in the thermophysical properties of the specific geological environment is reduced. Our underpinning science basis on GDF heat generation is summarised in our Engineered Barrier System Status Report.

Engineered Barriers System Status Report

For more information on geological disposal please visit our website at:

https://www.nuclearwasteservices.uk/disposal/geological-disposal

If you have any further questions or would like more information, please contact NWS Helpdesk o

info@nuclearwasteservices.uk

Kind regards

Joanne

NWS Helpdesk

www.nuclearwasteservices.uk.

Footprint of GDF by km2

Dear Marianne

Thank you for your email.

An indicative estimate of the underground footprint for a Geological Disposal Facility (GDF) is around 36 square kilometres in a lower strength sedimentary rock, such as that relevant to the Mid Copeland and South Copeland GDF Community Partnerships, based on the Inventory for Geological Disposal 2019. By footprint, we mean the area enclosing the underground elements of a GDF (e.g. logisticsarea, transfer tunnels, vaults, etc), only a fraction of this area will be excavated. The GDF footprint depends on several factors, including, the specific characteristics and setting of the host rock, the final design of the GDF concept, and the inventory for geological disposal. As the GDF programme moves forward, there will be greater certainty in these factors and it will be possible to provide a more accurate and precise estimate of footprint.

Kind regards

Lucy

NWS Helpdesk

“Pioneer Park”

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A related item on the Nuclear Issues Board agenda is the so called “Pioneer Park” on the green fields and river Ehen floodplain next to Sellafield. This is a vulnerable area which should be a permanantly guaranteed buffer zone between Sellafield and the surrounding villages. Dr Paul Dorfman outlines the problems of so called SMR’s in a letter published this week in the Times “Misgivings over nuclear reactors - Sir, Further to your report “Deal with US to fast-track mini nuclear reactors” (Sep 15; letter,Sep 16), small modular reactors (SMRs) are defined by the International Atomic Energy Agency as reactors that generate up to 300MW power.

At 470MW, the Rolls-Royce design is not an SMR: it is larger than the UK Magnox reactor, more than half the size of the 900MW reactors that make up the bulk of the French nuclear fleet, and about a third the size of the very large EPR reactor design at Hinkley Point C. This matters because the Rolls-Royce design will need big sites, standard nuclear safety measures, exclusion zones, core catchers, aircraft crash protection and security.

All this is important because in calling its design an SMR, or small, Rolls-Royce appears to me to have been economical with the truth — and all that implies for its other claims, especially about time and cost. As for the nuclear waste problem, the former chair of the US government Nuclear Regulatory Commission reports that SMRs would produce more reactive waste per kWh — the key parameter —than large reactors.

Dr Paul Dorfman
Bennett Scholar, Bennett Institute for Innovation & Acceleration, University of Sussex; chair, Nuclear Consulting Group