Comments on submissions by McKirdy (NDA)
Submitted to MP’s fact finding on Radwaste in west Cumbria
Chair Sir Tony Cunningham
Prof Stuart Haszeldine, University of Edinburgh 10 Jan 2013
McKirdy
Line 2-5The BGS did not reject on geology, but on resource criteria. The BGS survey is also incomplete, as ingnored Category B aquifers in Solway Plain, and ignores potential shale gas licensing. Remaining areas are not certified as “suitable” by BGS, just not-excluded. Areas of National Park, SSI, AONB should also be excluded. Statement that west Cumbria has investigation potential is therefore not logical.
Line 8 Seems to admit that a geology barrier is needed for site performance
Line 13 It would be helpful to have references to reports or information.
Line 19This presumably refers to lines 146-148. The case is not made, as all these techniques were used by Nirex in mid-1990’s, and are cited and specified by Etec in the NDA generic GDF investigation plan (October 2010).
Line 21, 222This is the first of many vague assertions on suitability. What is OMITTED in all NDA work, is clear criteria for what is “adequate” to proceed, and especially what is a “fail” to indicate withdrawal. Instead, the philosophy appears to be that ever-increased investigation will somehow provide a high-quality GDF. This is logically and scientifically incorrect.
Line 26 – 28Again this is vague, and leaves the assessment of site performance to others, not the NDA. Clear, numerical and verifiable criteria are needed. This appears to be an unreasonably low hurdle quality standard, which can result in misleading illusion of “progress” to culminate in later failure.
Line 36 Multiple safety functions implies that geological containment has to be a positive setting, not a passive container (line 40).
Line 40If the role of geology is merely to contain the engineering of the near-field, that contradicts the statements in lines 8, 36. If line 40 is true, then a GDF could be constructed anywhere below the surface. Why, then, do all other nations do geological surveys and site selection?
Line 43This selective quoting of IAEA still shows that positive geological containment should be demonstrated. What is that in Cumbria?
Line 50- 52Here re some IAEA indications that geological setting nd not just rock type is important. The NDA approach, to just identify a rock type is simplistic, naïve and entirely ill-considered. This was the failed UK process of 1970’s. By the late 1980”s the UK had moved on to consider the geological setting with water flow, geo-chemistry, faults and fractures etc included. Why not use that now?
Line 59 – 60This is not true for west Cumbria. For example radioactive 14C exceeds the simple safety case by at least 1,000-fold during early years of GDF (e.g. Galson sciences 2007, for Nirex, then NDA)
Line 62I think the Swedish rocks are gneiss (metamorphic) , not granite. Where are the gneiss, clays and mudstones in Cumbria ?
Line 69The copper concept is now shown to corrode at least 100-1,000 fold too rapidly. This is not a secure proposition.
Line 70If the rock merely provides protection, then any rock anywhere will do?
Line 74If the BVG is the geological barrier in the UK, these are metamorphosed volcanic rock (not granite). Where is that analogue from European sites alluded to in lines 61, 62 and elsewhere?
Line 74Nirex 97 was a clear fail of the safety case , as was Nirex 95. See statements by inquiry Inspector in MRWS 267 – march 2012. Nirex 95 and 97 treated geological faults as “invisible” with water flow characterisitics the same as surrpunding rock. That is scientifically appalling, and incorrect.
Line 80 – 82Because a lot of legacy information exists for Cumbria form Nirex and other investigations, these simulations of site performance can be undertaken NOW, in a scoping excercise. If not, why not?
Line 84 See Line 2- 5. Also the National Park etc should be excluded. If this is deliberately left in, that implies the Park is a target.
Line 85If the rock types remaining are similar to other countries, that implies the BVG is Excluded, as that does not exist elsewhere.
Line 87 – 95This ignores the substantial regional 60x80km surveys by Nirex
Line 102 – 110This is a mis-reading of the Inquiry report which is willful and reckless. The Inspector and Assessor clearly state that west Cumbrian d the Longlands Site are unsuitable. Whilst hesitating to exclude all of west Cumbria on the available evidence, the Inquiry clearly recommended never returning to to west Cumbria, and seeking better sites in the east of the UK.
Line 114 – 117Nirex 97 just put detail onto a flawed site and a flawed model. See Line 74.
Line 118 – 119Does this suggest that NDA do not accept that Planning Inquiry inspectors have expertise, expert advice, and judgement ?
Line 120 – 123If this means what it appears to say, then this is an extremely dangerous UK process, where permission can be granted before the investigation takes place.
Line 126Not true, there is abundant information. NDA should read and reflect on the MRWS 2012 Consultation submissions by Smythe and by Haszeldine.
Line 127Does this mean that more invasive investigation is needed before MRWS – 5 ? If not, how will multiple candidate sites be sieved down to selct just one for the invasive investigations and birehoels etc implied in lines 133- 141
Line 133 – 141At what stage of MRWS is this ? Much of this regional survey work has already been done by Nirex. Would boreholes ever be considered in the National Park. How would those be justified, unless a potential site was beneath the National Park.
Line 142 – 143This is silent on the known difficulty of avoiding water flow through fractured rock in west Cumbria. A large part of the ILW GDF in the reference design may be void space, one fracture flow (and there are many) therefore fills ALL the GDF with flowing water.
Line 146 – 148All these technologies were used during the 1990’s. Improvements do exist in level of precision (usually, rather than accuracy). So this perhaps finds the same fractures to within centimetres, rather than metres.
Line 157west Cumbria is complex – relative to what ?
Line 161 -165It would be very helpful to have an indication of examples that the NDA considers may be suitable sites in Cumbria.
Stuart Haszeldine 10 Jan 2013
Comments to Cumbria MP’s Radwaste fact finding 10 Jan page 1/3